ML23095A020

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Enclosure 2 - ITS Section 3.8 Electrical Power Systems, Revision 2, Volume 13
ML23095A020
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 04/04/2023
From:
Florida Power & Light Co
To:
Office of Nuclear Reactor Regulation
Shared Package
ML23095A006 List:
References
L-2023-043
Download: ML23095A020 (1)
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Text

ENCLOSURE 2 VOLUME 13 TURKEY POINT NUCLEAR GENERATING STATION UNIT 3 AND UNIT 4 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.8 ELECTRICAL POWER SYSTEMS Revision 2 R2

LIST OF ATTACHMENTS

1. ITS 3.8.1 - AC Sources - Operating
2. ITS 3.8.2 - AC Sources - Shutdown
3. ITS 3.8.3 - Diesel Fuel Oil, Lube Oil, and Starting Air
4. ITS 3.8.4 - DC Sources - Operating
5. ITS 3.8.5 - DC Sources - Shutdown
6. ITS 3.8.6 - Battery Parameters
7. ITS 3.8.7 - Inverters - Operating
8. ITS 3.8.8 - Inverters - Shutdown
9. ITS 3.8.9 - Distribution Systems - Operating
10. ITS 3.8.10 - Distribution Systems - Shutdown
11. Relocated/Deleted Current Technical Specifications (CTS)
12. ISTS Not Adopted

ATTACHMENT 1 ITS 3.8.1, AC SOURCES - OPERATING

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS A01 ITS 3.8.1 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES A02 OPERATING qualified circuits between the offsite transmission network and the unit LA01 LIMITING CONDITION FOR OPERATION onsite Class 1E AC Electrical Power Distribution System LCO 3.8.1 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE: M06 Add proposed LCO 3.8.1.c LCO 3.8.1.a a. Two startup transformers and their associated circuits, and A02 Two unit emergency capable of supplying the onsite Class 1E power distribution subsystem(s),

LCO 3.8.1.b b. Three separate and independent diesel generators* including, LCO 3.8.1.d LA02 Add proposed LCO 3.8.1.d

1) For Unit 3, two (3A and 3B); for Unit 4, one (3A or 3B) each with:

M06 SR 3.8.1.3 a) A separate skid-mounted fuel tank and a separate day fuel tank with an OPERABLE solenoid valve to permit gravity flow from the day tank to the skid LA10 mounted tank, and with the two tanks together containing a minimum of 2000 gallons of fuel oil.

b) A common Fuel Storage System containing a minimum volume of 38,000 gallons of fuel,**

See ITS SR 3.8.1.5 c) A separate fuel transfer pump,** 3.8.3 d) Lubricating oil storage containing a minimum volume of 120 gallons of lubricating oil, e) Capability to transfer lubricating oil from storage to the diesel generator unit, and f) Energized MCC bus (MCC 3A vital section for EDG 3A, MCC 3K for EDG 3B).

LA03 LCO 3.8.1.b 2) For Unit 3, one (4A or 4B); for Unit 4, two (4A and 4B) each with:

SR 3.8.1.3 a) A separate day fuel tank containing a minimum volume of 230 gallons of fuel, b) A separate Fuel Storage System containing a minimum volume of 34,700 gallons of fuel, See ITS SR 3.8.1.5 c) A separate fuel transfer pump, and 3.8.3 d) Energized MCC bus (MCC 4J for EDG 4A, MCC 4K for EDG 4B). LA03

c. Automatic load sequencers for Train A and Train B A03 M06
  • Whenever one or more of the four EDG's is out-of-service, ensure compliance with the EDG requirements specified in Specifications 3.5.2 and 3.8.2.1.
    • A temporary Class III fuel storage system containing a minimum volume of 38,000 gallons of fuel oil may be used for up to 10 days during the performance of Surveillance Requirement 4.8.1.1.2i.1 for the Unit 3 storage tank while Unit 3 is in Modes 5, 6, or defueled. If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively.

See ITS 3.8.3 TURKEY POINT - UNITS 3 & 4 3/4 8-1 AMENDMENT NOS. 197 AND 191 Page 1 of 11

ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION: A10 Actions Note NOTE: LCO 3.0.4.b is not applicable to diesel generators. R2 unit or one required opposite unit offsite LA01 Action A a. With one of two startup transformers or an associated circuit inoperable:

Action B Required Action (RA) A.1 1. Demonstrate the OPERABILITY of the other startup transformer and its associated RA B.1 circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

RA A.2 2. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of no offsite power to one train concurrent with RA B.2 inoperability of redundant required feature(s), declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable. LA01 offsite circuit Action A 3. If the inoperable startup transformer is the associated startup transformer and became A01 R2 inoperable while the unit is in Mode 1: unit M01 a) Reduce THERMAL POWER to 30% RATED THERMAL POWER within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or unit offsite LA01 R2 RA A.3 b) Restore the inoperable startup transformer and associated circuits to A12 72 OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or in accordance with the Risk L02 Informed Completion Time Program, or be in at least HOT STANDBY within the Action H next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. R2 MODE 4 12 LA01

4. If THERMAL POWER is reduced to 30% RATED THERMAL POWER within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or RA B.3 if the inoperable startup transformer is associated with the opposite unit, restore the offsite M01 startup transformer and its associated circuits to OPERABLE status within 30 days of the loss of OPERABILITY, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Action I COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. R2 L02 MODE 4 18 offsite LA01 RA A.3 5. If the inoperable startup transformer is the associated startup transformer and became inoperable while the unit was in MODE 2, 3, or 4, restore the startup transformer and its associated circuits to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or in accordance with the Risk 72 Action H Informed Completion Time Program, or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and R2 in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units simultaneously. L01 MODE 4 12 A05 L02 L01 TURKEY POINT - UNITS 3 & 4 3/4 8-2 AMENDMENT NOS. 287 AND 281 Page 2 of 11

ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

ACTION (Continued)

Action C b. With one of the required diesel generators inoperable: offsite circuits LA01 RA C.1 1. Demonstrate the OPERABILITY of the above required startup transformers and their associated circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

LA04

2. If the diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining required diesel RA C.3.2 generators by performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless the absence of any potential common mode failure for the remaining diesel generators is RA C.3.1 determined. If testing of remaining required diesel generators is required, this testing must be performed regardless of when the inoperable diesel generator is restored to OPERABILITY. L03 RA C.4
3. Restore the inoperable diesel generator to OPERABLE status within 14 days** or in accordance with the Risk Informed Completion Time Program, or be in at least HOT Action H STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following R2 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. MODE 4 12 L02 RA E.1 Note NOTE: Enter applicable Actions of LCO 3.8.3.1, Onsite Power Distribution - Operating, when ACTION c is entered with no AC power source to any train. R2 or two required A13 Action E c. With one startup transformer and one of the required diesel generators inoperable:

offsite circuit LA01 RA A.1 1. Demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a on the remaining startup transformer and associated circuits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. LA04 L04

2. If the diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> maintenance or testing, demonstrate the OPERABILITY of the remaining required diesel RA C.3.2 generators by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, unless it can be confirmed that the cause of the inoperable diesel generator does not exist on the RA C.3.1 remaining required diesel generators, unless the diesel generators are already operating.

If testing of remaining required diesel generators is required, this testing must be LA04 performed regardless of when the inoperable diesel generator is restored to OPERABILITY.

L05 RA E.1, 3. Restore one of the inoperable sources to OPERABLE status in accordance with RA E.2 ACTIONS a and b, as appropriate.

Action A, 4. Restore the other A.C. power source (startup transformer or diesel generator) to Action B, OPERABLE status in accordance with the provisions of Section 3.8.1.1 ACTION a or b, Action C as appropriate, with the time requirement of that ACTION based on the time of initial loss of the remaining inoperable A.C. power source.

RA E.2 ** 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if inoperability is associated with Action Statement 3.8.1.1.c.

TURKEY POINT - UNITS 3 & 4 3/4 8-2A AMENDMENT NOS. 287 AND 281 Page 3 of 11

ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

ACTION (Continued)

d. With one diesel generator inoperable, in addition to ACTION b. or c. above, verify that:

L06

1. All required systems, subsystems, trains, components, and devices (except safety injection pumps) that depend on the remaining required OPERABLE diesel generators as RA C.2 a source of emergency power are also OPERABLE.

4 L07 If this condition is not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, be in at least HOT STANDBY within the Action H next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODE 4 12 L02 R2

2. At least two Safety Injection pumps are OPERABLE and capable of being powered from their associated OPERABLE diesel generators.

L06 If this condition is not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This ACTION applies to both units simultaneously.

offsite circuits LA01 Action D e. With two of the above required startup transformers or their associated circuits inoperable:

unit offsite circuits or three A10 RA D.1 1. Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from discovery of two offsite circuits inoperable concurrent with inoperability of redundant required feature(s), declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

offsite circuits LA01

2. Restore at least one of the inoperable startup transformers to OPERABLE status within RA D.2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />s* and in COLD A08 Action H SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units R2 simultaneously. Add proposed Required Action I.1, I.2 and Note L02 R2 offsite circuits RA A.1, 3. With only one startup transformer and associated circuits restored, perform Surveillance RA B.1 Requirement 4.8.1.1.1.a on the OPERABLE Startup transformer at least once per 8 R2 hours, and restore the other startup transformer and its associated circuits to OPERABLE LA01 status or shutdown in accordance with the provisions of ACTION 3.8.1.1.a with time requirements of that ACTION based on the time of initial loss of a startup transformer.

This ACTION applies to both units simultaneously. offsite circuit LA01 A05 L08 Action I *If the opposite unit is shutdown first, this time can be extended to 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />.

TURKEY POINT - UNITS 3 & 4 3/4 8-3 AMENDMENT NOS. 287 AND 281 Page 4 of 11

ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS L09 LIMITING CONDITION FOR OPERATION (Continued)

ACTION (Continued) LA01 offsite Action F f. With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of R2 RA C.1 two startup transformers and their associated circuits by performing the requirements of L09 required R2 Specification 4.8.1.1.1a. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least RA F.1 one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT R2 Action H STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. R2 Restore all required diesel generators to OPERABLE status within 14 days from time of initial loss RA C.4 or in accordance with the Risk Informed Completion Time Program, or be in at least HOT Action H STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> L02

g. Following the addition of the new fuel oil* to the Diesel Fuel Oil Storage Tanks, with one or more diesel generators with new fuel oil properties outside the required Diesel Fuel Oil Testing Program limits, restore the stored fuel oil properties to within the required limits within 30 days.
h. With one or more diesel generators with stored fuel oil total particulates outside the required Diesel Fuel Oil Testing Program limits, restore the fuel oil total particulates to within the required limits within 7 days.

See ITS 3.8.3 R2 Add proposed Action G A06 R2 A08 Add proposed Action I R2 L08 Add proposed Action J A07 R2 See ITS 3.8.3

  • The properties of API Gravity, specific gravity or an absolute specific gravity; kinematic viscosity; clear and bright appearance; and flash point shall be confirmed to be within the Diesel Fuel Oil Testing Program limits, prior to the addition of the new fuel oil to the Diesel Fuel Oil Storage Tanks.

TURKEY POINT - UNITS 3 & 4 3/4 8-4 AMENDMENT NOS. 287 AND 281 Page 5 of 11

ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS offsite circuit LA01 4.8.1.1.1 Each of the above required startup transformers and their associated circuits shall be:

SR 3.8.1.1 a. Determined OPERABLE in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignments, indicated power availability, and L10 SR 3.8.1.7 b. Demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program while shutting down, by transferring manually unit power supply from the auxiliary transformer to the startup transformer.

TURKEY POINT - UNITS 3 & 4 3/4 8-5 AMENDMENT NOS. 263 AND 258 Page 6 of 11

ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS SURVEILLANCE REOUIREMENTS (Continued) 4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE*:

a. In accordance with the Surveillance Frequency Control Program by:

SR 3.8.1.3 1) Verifying the fuel volume in the day and skid-mounted fuel tanks (Unit 4-day tank only),

2) Verifying the fuel volume in the fuel storage tank, See ITS 3.8.3
3) Verifying the lubricating oil inventory in storage, SR 3.8.1.6 4) Verifying the diesel starts and accelerates to reach a generator voltage and frequency of 3950-4350 volts and 60 + 0.6 Hz. In accordance with the Surveillance Frequency Control Program, these conditions shall be reached within 15 seconds after the start signal from normal conditions. For all other starts, warmup procedures, such as idling and gradual SR 3.8.1.2 Note 1 acceleration as recommended by the manufacturer may be used. The diesel generator shall be started for this test by using one of the following signals:

a) Manual, or b) Simulated loss-of-offsite power by itself, or LA05 c) Simulated loss-of-offsite power in conjunction with an ESF Actuation test signal, or d) An ESF Actuation test signal by itself.

SR 3.8.1.2 5) Verifying the generator is synchronized, loaded** to 2300 - 2500 kW (Unit 3), 2650-2850 LA06 kW (Unit 4)***, operates at this loaded condition for at least 60 minutes and for Unit 3 until automatic transfer of fuel from the day tank to the skid mounted tank is demonstrated, and the cooling system is demonstrated OPERABLE.

6) Verifying the diesel generator is aligned to provide standby power to the associated emergency buses. A11 add proposed SR 3.8.1.2 Note 3 M02 add proposed SR 3.8.1.2 Note 4 M03 SR 3.8.1.6 Note, SR 3.8.1.10 Note 1 SR 3.8.1.11 Note 1 SR 3.8.1.14 Note 2
  • All diesel generator starts for the purpose of these surveillances may be proceeded by a prelube period as SR 3.8.1.18 Note 1 recommended by the manufacturer.

SR 3.8.1.19 Note SR 3.8.1.2 ** May include gradual loading as recommended by the manufacturer so that the mechanical stress and wear on Note 1 the diesel engine is minimized.

SR 3.8.1.2 Note 2 ***Momentary transients outside these load bands do not invalidate this test.

TURKEY POINT - UNITS 3 & 4 3/4 8-6 AMENDMENT NOS. 263 AND 258 Page 7 of 11

ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

Add proposed SR 3.8.1.5 Note A04 SR 3.8.1.5 b. Demonstrating that a fuel transfer pump starts automatically and transfers fuel from the storage system to the day tank, in accordance with the Surveillance Frequency Control Program; L11 SR 3.8.1.4 c. In accordance with the Surveillance Frequency Control Program and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the day and skid-mounted fuel tanks (Unit 4-day tank only);

d. In accordance with the Surveillance Frequency Control Program by checking for and removing accumulated water from the fuel oil storage tanks; See ITS 3.8.3
e. By verifying fuel oil properties of new fuel oil are tested in accordance with, and maintained within SR 3.8.1.8 Note 1, the limits of, the Diesel Fuel Oil Testing Program.

SR 3.8.1.9 Note 1, SR 3.8.1.10 Note 2, f. By verifying fuel oil properties of stored fuel oil are tested in accordance with, and maintained SR 3.8.1.11 Note 2, SR 3.8.1.12 Note, within the limits of, the Diesel Fuel Oil Testing Program.

SR 3.8.1.15 Note, SR 3.8.1.16 Note, g. In accordance with the Surveillance Frequency Control Program, during shutdown (applicable to SR 3.8.1.17 Note, only the two diesel generators associated with the unit):

SR 3.8.1.18 Note 2 L12 Add proposed SR 3.8.1.8 through SR 3.8.1.12 and SR

1) Deleted 3.8.1.15 through SR 3.8.1.18 MODE restriction NOTE its associated single largest post-accident load LA08 SR 3.8.1.8 2)* Verifying the generator capability to reject a load of greater than or equal to 392 kW without exceeding a frequency of 66.25 Hz. Within 2 seconds following the load rejection, the generator shall return to within 3950-4350 volts and frequency at L12 60 +/- 0.6 Hz; add proposed SR 3.8.1.8 Note 1 add proposed SR 3.8.1.8 Note 2 M04 SR 3.8.1.9 3)* Verifying the generator capability to reject a load of greater than or equal to 2500 kW (Unit 3), 2874 kW (Unit 4) without tripping. The generator voltage shall return to less than or equal to 4784 volts within 2 seconds following the load rejection; L12 add proposed SR 3.8.1.9 Note 2 SR 3.8.1.10 4) Simulating a loss-of-offsite power by itself, and: add proposed SR 3.8.1.9 Note 2 M04 On an actual or simulated a) Verifying deenergization of the emergency busses and load shedding from the emergency busses, and L13
b. Verifying the diesel starts on the auto-start signal, energizes the emergency busses with any permanently add proposed SR 3.8.1.10 Note 2 L12 A09
  • For the purpose of this test, warmup procedures, such as idling, gradual acceleration, and gradual loading as recommended by the manufacturer may be used.

TURKEY POINT - UNITS 3 & 4 3/4 8-7 AMENDMENT NOS. 285 AND 279 Page 8 of 11

ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

L19 connected loads within 15 seconds, energizes the autoconnected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the auto-connected shutdown loads. After automatic load sequencing, the steady-state voltage and frequency of the emergency busses shall be maintained at 3950-4350 volts and 60 +/- 0.6 Hz during this test.

actual or simulated L13 SR 3.8.1.11 5) Verifying that on an ESF Actuation test signal, without loss-of-offsite power, the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The generator voltage and frequency shall be 3950-4350 volts and M05 3950 V and 59.4 Hz 60 +/- 0.6 Hz within 15 seconds after the auto-start signal; the steady-state generator voltage and frequency shall be maintained within these limits during this test; add proposed SR 3.8.1.11 requirements d and e

6) Simulating a loss-of-offsite power in conjunction with an ESF Actuation test signal, and:

On an actual or simulated actual or simulated L13 a) Verifying deenergization of the emergency busses and load shedding from the emergency busses; add proposed SR 3.8.1.18 Note 2 L12 b) Verifying the diesel starts on the auto-start signal, energizes the emergency busses with any permanently connected loads within 15 seconds, energizes the SR 3.8.1.18 auto-connected emergency (accident) loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads. After automatic load sequencing, the steady-state voltage and frequency of the emergency busses shall be maintained at 3950-4350 volts and 60 +/- 0.6 Hz during this test; and SR 3.8.1.12 c) Verifying that diesel generator trips that are made operable during the test mode of diesel operation are inoperable.

add proposed SR 3.8.1.12 Note 1 L12 SR 3.8.1.13 7)* # Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be loaded to 2550-2750 kW (Unit 3), 2950-3150 kW (Unit 4)** and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be L14 loaded to 2300-2500 kW (Unit 3), 2650-2850 kW (Unit 4)**. The generator voltage and frequency shall be 3950-4350 volts and 60 +/- 0.6 Hz within 15 seconds after the start signal; the steady-state generator voltage and frequency add proposed SR 3.8.1.13 Note 2 M04 SR 3.8.1.14 Note 2

  • For the purpose of this test, warmup procedures, such as idling, gradual acceleration, and gradual loading as SR 3.8.1.13 recommended by the manufacturer may be used.

Note 1, SR 3.8.1.14 Note 1

    • Momentary transients outside these load bands do not invalidate this test.

SR 3.8.1.13 # This test may be performed during POWER OPERATION TURKEY POINT - UNITS 3 & 4 3/4 8-8 AMENDMENT NOS. 260 AND 255 Page 9 of 11

ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) shall be maintained within these limits during this test. Within 5 minutes after completing SR 3.8.1.14 this 24-hour test, verify the diesel starts and accelerates to reach a generator voltage and L15 frequency of 3950-4350 volts and 60 +/- 0.6 Hz within 15 seconds after the start signal.**

3950 V and 59.4 Hz

8) Verifying that the auto-connected loads to each diesel generator do not exceed 2500 kW L19 (Unit 3), 2874 kW (Unit 4);

L16 SR 3.8.1.15 9) Verifying the diesel generators capability to:

a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power, b) Transfer its loads to the offsite power source, and c) Be restored to its standby status.

add proposed SR 3.8.1.15 Note L12 SR 3.8.1.16 10) Verifying that the diesel generator operating in a test mode, connected to its bus, a simulated Safety Injection signal overrides the test mode by: (1) returning the diesel L13 generator to standby operation, and (2) automatically energizing the emergency loads actual or with offsite power; add proposed SR 3.8.1.16 Note L12

11) Verifying that the fuel transfer pump transfers fuel from the fuel storage tank (Unit 3), fuel storage tanks (Unit 4) to the day tanks of each diesel associated with the unit via the installed cross-connection lines; LA09
12) Verifying that the automatic load sequence timer is OPERABLE with the interval between SR 3.8.1.17 each load block within +/- 10% of its design interval; add proposed SR 3.8.1.17 Note L12
13) Verifying that the diesel generator lockout relay prevents the diesel generator from starting; L17 L15
    • If verification of the diesels ability to restart and accelerate to a generator voltage and frequency of 3950-4350 volts and 60 +/- 0.6 Hz within 15 seconds following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operation test of Specification 4.8.1.1.2.g.7) is not satisfactorily completed, it is not necessary to repeat the 24-hour test.

Instead, the diesel generator may be operated between 2300-2500 kW Unit 3, 2650-2850 kW (Unit 4) for SR 3.8.1.14 Note 1 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until operating temperature has stabilized (whichever is greater). Following the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s/operating temperature stabilization run, the EDG is to be secured and restarted within 5 minutes SR 3.8.1.14 to confirm its ability to achieve the required voltage and frequency within 15 seconds.

TURKEY POINT - UNITS 3 & 4 3/4 8-9 AMENDMENT NOS. 260 AND 255 Page 10 of 11

ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

L18 SR 3.8.1.19 h. In accordance with the Surveillance Frequency Control Program or after any modifications which could affect diesel generator interdependence by starting all required diesel generators simultaneously and verifying that all required diesel generators provide 60 +/- 0.6 Hz frequency and 3950-4350 volts in less than or equal to 15 seconds: and L19 3950 V and 59.4 Hz

i. In accordance with the Surveillance Frequency Control Program, by draining each fuel oil storage tank, removing the accumulated sediment and cleaning the tank.*
j. At least once per 10 years, for Unit 4 only, by performing a pressure test of those portions of the diesel fuel oil system designed to Section III, subsection ND of the ASME Code in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda.

See ITS 3.8.3 4.8.1.1.3 Reports - (Not Used)

See ITS 3.8.3

  • A temporary Class III fuel storage system containing a minimum volume of 38,000 gallons of fuel oil may be used for up to 10 days during the performance of Surveillance Requirement 4.8.1.1.2i for the Unit 3 storage tank while Unit 3 is in Modes 5, 6, or defueled. If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively.

TURKEY POINT - UNITS 3 & 4 3/4 8-10 AMENDMENT NOS. 263 AND 258 Page 11 of 11

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS Limiting Condition for Operation (LCO) 3.8.1.1.a requires two startup transformers and their associated circuits to be OPERABLE. CTS LCO 3.8.1.1.b requires three separate and independent diesel generators to be OPERABLE.

ITS LCO 3.8.1.a requires two qualified circuits between the offsite transmission network and the unit onsite Class 1E AC Electrical Power Distribution System be OPERABLE. ITS LCO 3.8.1 b states "Two unit emergency diesel generators (EDGs) capable of supplying the onsite Class 1E power distribution train(s),"

shall be OPERABLE. ITS LCO 3.8.1.c requires one qualified circuit between the offsite transmission network and the opposite unit onsite Class 1E AC Electrical Power Distribution train(s) needed to support equipment required by LCO 3.5.2, ECCS - Operating, LCO 3.7.10, Control Room Emergency Ventilation System (CREVS), and LCO 3.7.11, Control Room Emergency Air Temperature Control System (CREATCS)," and LCO 3.8.4, DC Sources - Operating, be OPERABLE. ITS 3.8.1.d requires the opposite unit EDG(s) capable of supplying power to support equipment required by LCO 3.5.2, LCO 3.7.10, LCO 3.7.11, and LCO 3.8.4 shall be OPERABLE. This changes the CTS by clarifying the qualified offsite circuit(s), which includes the startup transformers, is the circuit path from the transmission network to the required Class 1E AC Electrical Power Distribution train(s) required to support the unit's operation and that the EDGs are capable of supplying the required electrical power to the distribution trains that they serve.

The purpose of AC Sources LCO is to ensure qualified onsite and offsite AC sources are available to support equipment required in a design basis event.

The change clarifies that a qualified circuit is between the transmission network to the onsite Class 1E AC Electrical Distribution System and that required EDGs must be capable of supplying the onsite Class 1E power distribution trains(s).

Also, the explicit requirements for required opposite unit AC Sources is not included in CTS 3.8.1.1. However, opposite unit AC sources are required to be OPERABLE to support the emergency core cooling system (ECCS), CREVS, CREATCS, and DC Sources. Therefore, the change clarifies the Specifications for equipment which require an opposite unit offsite circuit and opposite unit EDGs. Due to the shared systems between the units and a common set of Technical Specifications for both PTN units, the current Specification is presented on a facility basis instead of a unit basis. The ITS presentation reflects the PTN multi-unit and shared systems design on a unit basis to more clearly define the AC Source requirements for each licensed unit. Justification for Turkey Point Unit 3 and Unit 4 Page 1 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING technical changes associated with the LCO are provided in other Discussion of Changes. The PTN Class 1E AC Electrical Power Distribution System design consists of shared power supplies and AC Sources. This presentation of the LCO is consistent with the ITS presentation at other sites that utilize shared systems: For example: Catawba Nuclear Station Units 1 and 2 Technical Specifications, LCO 3.8.1, AC Sources - Operating, (NRC ADAMS Accession No. ML052990150), Edwin I. Hatch Nuclear Plant Unit 1 Technical Specifications, LCO 3.8.1, AC Sources - Operating, (NRC ADAMS Accession No. ML052930172), and Donald C. Cook Nuclear Plant Unit 1 Technical Specifications, LCO 3.8.1, AC Sources - Operating, (NRC ADAMS Accession No. ML053050305). This clarification change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS LCO 3.8.1.1 does not contain a requirement for the sequence timers associated with surveillance requirement 4.8.1.1.2.g.12. ITS LCO 3.8.1.e, requires the automatic load sequencers for Train A and Train B to be OPERABLE. This changes the CTS by specifically stating the LCO requirement for the sequence timer(s).

This change is acceptable because the addition of the sequencers to the LCO does not change the technical requirements of the CTS. The CTS essentially requires them to be OPERABLE but does not provide an LCO or Action Requirements. The addition of the sequence timer(s) does not add or delete any technical requirements to the CTS. This change is designated as administrative because the technical requirements of the specifications have not changed.

A04 CTS 3.8.1.1.b.1.c (OPERABILITY of a separate fuel transfer pump) footnote **

states, in part, that a temporary Class III fuel storage system containing a minimum volume of 38,000 gallons of fuel oil may be used for up to 10 days during the performance of Surveillance Requirement (SR) 4.8.1.1.2.i.1 (Note that PTN License Amendments 263 and 258 (ML15166A320) changed CTS 4.8.1.1.2.i.1 to CTS 4.8.1.1.2.i but missed correcting this in the CTS LCO footnote) for the Unit 3 storage tank while Unit 3 is in MODES 5, 6, or defueled.

ITS SR 3.8.1.5 (verify the fuel oil transfer system operates to automatically transfer fuel oil from the storage tank to the day tanks) Note states that this SR is not required to be met for Unit 3 EDGs during use of a temporary Class III fuel storage system as allowed by LCO 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air." This changes the CTS by referencing the ITS location that the allowance will be linked to.

This change is acceptable because it does not change the technical requirements of the CTS. CTS 3.8.1.1.b.1.b, CTS 3.8.1.1.b.1.c, and CTS 4.8.1.1.2.i contain the same footnote associated with the allowance for a temporary Class II fuel storage system. CTS 3.8.1.1.b.1.b and CTS 4.8.1.1.2.i requirements are being moved to a new ITS LCO 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air." Because the allowance for a temporary fuel oil storage system mostly concerns the fuel oil storage volume and the cleaning of the fuel oil storage tank, the appropriate location for the allowance is ITS LCO 3.8.3.

However, because the temporary fuel storage system will not use the fuel oil transfer pumps, a Note is added to SR 3.8.1.5 stating that this SR is not required Turkey Point Unit 3 and Unit 4 Page 2 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING to be met for Unit 3 EDGs during use of a temporary Class III fuel storage system as allowed by LCO 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air." The ITS requirements are consistent with the CTS requirements. This change is designated as administrative because the technical requirements of the specifications have not changed.

A05 CTS 3.8.1.1, ACTIONS a.5, e.2, and e.3, include a statement that the action applies to both units simultaneously. ITS 3.8.1, does not explicitly state that the ACTIONS apply to both units because the statement is redundant to the requirements of CTS 3.0.5.a (ITS LCO 3.0.10.a). This changes the CTS by deleting redundant detail.

The purpose of the CTS statement is to ensure action requirements are performed simultaneously for both units when required equipment shared between the units is inoperable. This statement is redundant to the generic requirement provided in CTS 3.0.5.a (ITS LCO 3.0.10.a) and, therefore, is not necessary. ITS LCO 3.0.10.a states, "Whenever the LCO refers to systems or components which are shared by both units, the Conditions and Required Actions will apply to both units simultaneously." As a result, applying Technical Specification requirements to both units simultaneously is required for all requirements associated with an LCO that refers to systems and components shared by both units, irrespective of whether an explicit statement is provided or not. Technical Specification ACTIONS associated with shared systems will continue to be performed for both units simultaneously per the requirements of ITS LCO 3.0.10.

This change is solely a presentation preference and is designated as administrative because it does not result in a technical change to the CTS.

A06 CTS SR 4.8.1.1.2 states that each EDG shall be demonstrated OPERABLE.

CTS SR 4.8.1.1.2.g.12 is associated with EDG OPERABILITY and states to verify that the automatic load sequence timer is OPERABLE with the interval between each load block within +/- 10% of its design interval. If the requirement of CTS SR 4.8.1.1.2.g.12 cannot be met, the EDG is declared inoperable, and the appropriate Actions are entered. ITS LCO 3.8.1.e requires that the automatic load sequencers for Train A and Train B shall be OPERABLE. ITS 3.8.1 R2 ACTION G requires that with one automatic load sequencer inoperable, to restore the automatic load sequencer to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program. This changes the CTS by providing a specific Condition for an inoperable automatic load sequencer with a stated Required Action.

This change is acceptable because it does not change the technical requirements of the CTS. The CTS requires the sequence timer(s) to be OPERABLE but does not provide an LCO or Action requirements. However, the CTS provides that if an automatic sequence timer(s) is inoperable the associated EDG is declared inoperable. CTS 3.8.1.1, ACTION b, provides Actions and associated Completion Times for one inoperable EDG. CTS 3.8.1.1, ACTION b.3, states to restore the inoperable EDG to OPERABLE status within 14 days** or in accordance with the Risk Informed Completion Time Program or Turkey Point Unit 3 and Unit 4 Page 3 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING shut down the unit. Footnote ** states that the Completion Time is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if EDG inoperability is associated with Action 3.8.1.1.c (one startup transformer and required EDG inoperable). Because the automatic load sequencer affects the load sequencing when the bus is powered from the EDG and the offsite power, the 72-hour Completion Time is appropriate. The addition of the sequence timer(s) does not add or delete any technical requirements to the CTS.

This change is designated as administrative because the technical requirements of the specifications have not changed.

A07 CTS 3.8.1.1 does not contain an Action for the combination of one or more required offsite circuits inoperable concurrent with two or more required EDGs inoperable, or one or more required EDGs inoperable concurrent with two or more required offsite circuits inoperable. These combination of inoperabilities would subsequently require entering CTS LCO 3.0.3 since the CTS does not address these configurations. ITS 3.8.1, Condition J, explicitly states the combination of AC source inoperabilities that warrant entry into LCO 3.0.3.

ITS 3.8.1, ACTION J, requires entering LCO 3.0.3 immediately if one or more required offsite circuits are inoperable concurrent with two or more required R2 EDGs inoperable; or one or more required EDGs are inoperable concurrent with two or more required offsite circuits inoperable. This changes the CTS by adding a specific ACTION requiring entry into LCO 3.0.3.

The change is acceptable because the CTS Action taken for the specified combination of inoperabilities are the same as the ITS ACTIONS. This change is designated as administrative because it does not result in a technical change to the CTS.

A08 CTS 3.8.1.1 Actions, in part, state, "This ACTION applies to both units simultaneously." In addition, CTS 3.8.1.1 Actions provide different Completion Times to shut down the Unit(s) to at least HOT STANDBY (MODE 3). Generally, two different Completion Times are used in CTS to reach HOT SHUTDOWN, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> based on how many units are being shutdown simultaneously. A variance of these Completion Times is used if a dual unit shutdown is required without offsite power (i.e., natural circulation cooldown required) that provides additional time to bring the units to COLD SHUTDOWN consecutively. ITS provides two different Actions depending on a single unit shut down (ACTION H) or dual unit shut down (ACTION I). This changes the CTS by R2 providing distinct separate Actions in each of the two different conditions.

CTS shutdown Actions and associated Completion Times provide a reasonable period to shut down the unit in an orderly manner without challenging unit systems, based on operating experience. When a single unit is affected, the time to be in Hot Standby is 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. When an ACTION statement requires a dual unit shutdown, the time to be in Hot Standby is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This is to allow the orderly shutdown of one unit at a time and not jeopardize the stability of the electrical grid by imposing a simultaneous dual unit shutdown. Without offsite power a consecutive shutdown is used because a unit without its associated transformer must perform a natural circulation cooldown. By completely shutting down one unit before starting shutdown of the second unit, a dual unit natural circulation cooldown is avoided. This change is acceptable because the CTS Turkey Point Unit 3 and Unit 4 Page 4 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING Actions are the same as the ITS Actions. This change is necessary due to the format of ITS. This change is designated as administrative because it does not result in a technical change to the CTS.

A09 CTS 4.8.1.1.2.g.2 and CTS 4.8.1.1.2.g.3 are provided with footnote

  • that states, "For the purpose of this test, warmup procedures, such as idling, gradual acceleration, and gradual loading as recommended by the manufacturer may be used." Corresponding ITS SR 3.8.1.8 and SR 3.8.1.9 do not include this footnote. This changes the CTS by removing a footnote allowing use of warmup procedures as recommended by the manufacturer.

The purpose of CTS 4.8.1.1.2.g.2 and CTS 4.8.1.1.2.g.3 is to verify the EDGs capability to reject its associated single largest load or base continuous rating load. CTS does not specify any starting criteria only that the load the EDG must be able to reject and the voltage the EDG must be able to attain within a specified period. Providing a starting allowance for a staring restriction that is not applicable is unnecessary and is deleted. This change is designated as administrative because it does not result in any technical change to the CTS.

A10 CTS 3.8.1.1 Action a provides requirements for the condition with one of two startup transformers or an associated circuit inoperable and requires the startup transformer and associated circuits to be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program.

CTS 3.8.1.1 Action a.4, in part, allows the time to restore the startup transformer and associated circuits to be restored to OPERABLE status within 30 days if the startup transformer is associated with the opposite unit. CTS 3.8.1.1 Action e provides requirements for the condition with two of the required startup transformers or their associated circuits inoperable. ITS LCO 3.8.1 more precisely defines the offsite circuits as two-unit offsite circuits and one opposite unit offsite circuit effectively requiring three offsite circuits (two-unit circuits and one opposite unit circuit). ITS 3.8.1 ACTION A provides requirements for the condition with one-unit offsite circuit inoperable and requires the circuit to be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program. ITS 3.8.1 ACTION B provides requirements for the condition with one opposite unit offsite circuit inoperable and requires the circuit to be restored to OPERABLE status within 30 days. ITS 3.8.1, ACTION D, provides requirements for the condition with unit offsite circuits inoperable or three offsite circuits inoperable. This change is a presentation change and does not represent a technical change since the condition of three offsite circuits R2 inoperable in ITS is equivalent to the CTS condition of two startup transformers or associated circuits inoperable.

The purpose of the CTS Actions a and e is to ensure appropriate remedial action is taken when one or more offsite circuits are inoperable. ITS LCO 3.8.1 more precisely defines the offsite circuits as two-unit offsite circuits and one opposite unit offsite circuit effectively requiring three offsite circuits (two-unit circuits and one opposite unit circuit). ITS provides one ACTION for an inoperable circuit if it is associated with the unit (including the circuit between the opposite unit startup transformer and the associated units Train A 4.16 kV bus) and one ACTION if the circuit inoperability is associated with the opposite unit 4.16 kV buses.

Turkey Point Unit 3 and Unit 4 Page 5 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING ITS 3.8.1 ACTION D provides the appropriate requirements when two-unit offsite circuits (i.e., unit offsite circuit paths from each startup transformer) are inoperable or three offsite circuits (i.e., all offsite circuit paths from both unit R2 startup transformers) are inoperable. This change in presentation is consistent with the intent of CTS Action e, which provides action when both startup transformers or associated circuits are inoperable. This change also aligns the R2 PTN ITS with the intent of ISTS 3.8.1, Condition C, which provides action when all offsite AC sources are inoperable while onsite AC sources continue to be available. This change is designated as administrative because it represents a presentation change and does not result in any technical change to the CTS.

A11 CTS 4.8.1.1.2.a.6 requires the verification that each EDG is aligned to provide standby power to the associated emergency buses. ITS 3.8.1 does not contain this surveillance requirement. This changes the CTS by deleting the surveillance requirement as the detail that each EDG is aligned to provide standby power to the associated emergency buses is included in the ITS LCO.

The removal of CTS 4.8.1.1.2.a.6, which is related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included as a specific surveillance requirement to provide adequate protection of public health and safety. ITS LCO 3.8.1 requires the R2 EDGs to be OPERABLE. For the emergency diesel generator to provide its safety function, as required by the definition of OPERABLE, it must be aligned to provide standby power, capable of providing power to the associated emergency bus as described in the Bases. This change is designated as administrative because it does not result in a technical change to the CTS.

A12 CTS 3.8.1.1 ACTION 3 provides actions if the inoperable startup transformer is the associated startup transformer and became inoperable. CTS 3.8.1.1 ACTION 3.a) provides an action to take within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If CTS 3.8.1.1 ACTION 3.a) is not completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CTS ACTION 3.b) provides an action to restore the inoperable associated startup transformer within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, for a total of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable, or in accordance with the Risk Informed Completion Time Program or commence a shutdown. ITS 3.8.1 Required Action A.3 requires that with one Unit (associated) offsite circuit inoperable to restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program or commence a shutdown. This changes the CTS by combining the Completion Times of CTS 3.8.1.1 ACTION 3.a) and ACTION 3.b) (24+48 = 72) into the ITS 3.8.1 Required Action A.3 of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

This change is designated as administrative because it does not result in a technical change to the CTS.

A13 CTS 3.8.1.1 Action c provides requirements for the condition with one startup transformer and one of the required diesel generators inoperable requiring restoration of one of the inoperable sources to OPERABLE status in accordance R2 with ACTIONS a and b, as appropriate. CTS 3.8.1.1.a states, in part, that as a minimum, the following A.C. electrical power sources shall be OPERABLE and Turkey Point Unit 3 and Unit 4 Page 6 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING includes two startup transformers and their associated circuits. ITS LCO 3.8.1 more precisely defines the offsite circuits required for each unit effectively requiring up to three offsite circuits (two-unit circuits and one opposite unit circuit, if required). ITS 3.8.1 ACTION E provides requirements for the condition with one unit or two required offsite circuits inoperable and one required EDG R2 inoperable requiring either the circuit(s) or the EDG to be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program. This changes the CTS presentation by using the more precise definition of the offsite circuits for each unit effectively requiring up to three offsite circuits (two-unit circuits and one opposite unit circuit).

The purpose of CTS 3.8.1.1 Action c is to ensure appropriate remedial action is taken when a startup transformer and a require EDG are inoperable. ITS LCO 3.8.1 more precisely defines the startup transformers and associated circuits as two-unit offsite circuits and one opposite unit offsite circuit between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System effectively requiring up to three offsite circuits. Thus, when an opposite unit startup transformer is inoperable, up to two offsite circuits may be inoperable to the subject unit; 1) the alternate offsite circuit to the subject units AC Electrical Power System Train A from the opposite unit startup transformer and, 2) the opposite unit offsite circuit from the same startup transformer to the opposite units AC Electrical Power Distribution System required to support necessary unit R2 shared equipment. ITS 3.8.1 Condition E applies to the combination of any one required offsite circuit inoperable concurrent with one required EDG inoperable.

This Condition also applies when a unit offsite circuit is inoperable concurrent with a required opposite unit offsite circuit inoperable (e.g., an opposite unit startup transformer is inoperable) and one required EDG inoperable. If two unit offsite circuits are inoperable concurrent with a required EDG inoperable, Condition J will also apply. (Refer to DOC A07 for the discussion of the addition of ITS 3.8.1 ACTION J). This change is designated as administrative because it represents a presentation change and does not result in any technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.1.1, ACTION a, provides actions when one of the two startup transformers or an associated circuit is inoperable. CTS, ACTIONS a.3, a.4, and a.5, provide different actions based on the unit's MODE and if the inoperable startup transformer and associated circuit is associated with the opposite unit. If the inoperability is associated with the unit's startup transformer or associated circuits and the unit is in MODE 1, CTS allows 30 days to restore the inoperable circuit if THERMAL POWER is reduced to 30% RATED THERMAL POWER within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or restore the inoperable circuit within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or in accordance with the Risk Informed Completion Time Program if THERMAL POWER is not reduced. If the inoperability is associated with the opposite unit's startup transformer or associated circuits, CTS also allows 30 days to restore the inoperable circuit. If the inoperability is associated with the unit's startup transformer or associated circuit and the unit is in MODE 2, 3, or 4, CTS allows a maximum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the inoperable circuit or in accordance with the Turkey Point Unit 3 and Unit 4 Page 7 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING Risk Informed Completion Time Program. ITS provides one ACTION for an inoperable circuit if it is associated with the unit (including the circuit between the opposite unit startup transformer and the associated units Train A 4.16 kV bus) and one ACTION if the circuit inoperability is associated with the opposite unit 4.16 kV buses. ITS 3.8.1, Required Action A.3, requires that with one-unit offsite circuit inoperable, to restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program. This changes the CTS actions for an inoperable circuit to the unit's 4.16 kV buses, whether from the unit startup transformer or the opposite unit startup transformer from 30 days to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Program.

The purpose of ITS 3.8.1, ACTION A, is to limit the time the unit can operate with an inoperable AC Source and to perform other compensatory measures. The proposed change is acceptable because the proposed Completion Time is consistent with the 72-hour Completion Time currently allowed when a startup transformer or an associated circuit is inoperable for the associated unit when in MODE 1 without a power reduction. The PTN electrical design includes one offsite circuit per unit that would be immediately available in the event of a design basis accident. The second offsite circuit (i.e., circuit path from the opposite unit startup transformer) is a delayed circuit that requires manual action to transfer power to the required onsite Class 1E Electrical Power Distribution System.

Therefore, it is concluded that limiting operation with one-unit offsite circuit inoperable to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program is appropriate. If the risk assessment supports operation for longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, operation may continue for up to 30 days in accordance with the Risk Informed Completion Time Program with a unit offsite circuit inoperable, which may also include a restriction to limit operation in MODE 1 less than 30% RTP to obtain a 30 day allowance. This change is designated as more restrictive because the Completion Time for restoring an inoperable startup transformer and associated circuits if associated with the unit (including the circuit between the opposite unit startup transformer and the associated units Train A 4.16 kV bus) without a risk assessment has been reduced.

M02 CTS 4.8.1.1.2.a.5 requires each EDG to be synchronized, loaded, and operated for at least 60 minutes. ITS SR 3.8.1.2 requires the same test; however, an additional Note has been added that places a restriction on the test. ITS SR 3.8.1.2 Note 3 modifies the CTS requirements by stating that this Surveillance shall be conducted on only one EDG at a time. This changes the CTS by adding a restriction when performing this test.

The purpose of CTS 4.8.1.1.2.a.5 is to ensure the EDG can supply the emergency loads. The added requirement to perform the SR on only one EDG at a time is acceptable because common cause failures that might result from offsite circuit or grid perturbations are avoided. In addition, CTS 4.8.1.1.2.a.5 is normally conducted on one EDG at a time. This change is designated as more restrictive because an explicit restriction is added to the EDG load test.

M03 CTS 4.8.1.1.2.a.5 requires each EDG to be synchronized, loaded, and operated for at least 60 minutes. ITS SR 3.8.1.2 requires the same test; however, an additional Note has been added that places a restriction on the test. ITS Turkey Point Unit 3 and Unit 4 Page 8 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING SR 3.8.1.2 Note 4 modifies the CTS requirements by stating that the SR shall be preceded by and immediately follow, without a shutdown of the EDG, a successful performance of ITS SR 3.8.1.6 (timed start of the EDG). This changes the CTS by adding a restriction when performing this test.

The purpose of CTS 4.8.1.1.2.a.5 is to ensure the EDG can supply the emergency loads. This change is acceptable because it eliminates an EDG start, which reduces mechanical stress and wear on the EDG. In addition, EDG loading during performance of CTS 4.8.1.1.2.a.5 is usually conducted without shut down after a successful start during performance of CTS 4.8.1.1.2.a.4. This change is designated as more restrictive because an explicit restriction is added to the EDG load test.

M04 CTS 4.8.1.1.2.g.2 requires the testing of each EDG with a load rejection greater than or equal to 392 kW. CTS 4.8.1.1.2.g.3 requires the testing of each EDG with a load rejection of 2500 kW. CTS 4.8.1.1.2.g.7 requires verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under specific loaded conditions. These Surveillances do not specify that the testing be performed at a specific power factor. ITS SR 3.8.1.8 requires the verification that each EDG can reject a load equal to or greater than its associated single largest post-accident load. ITS SR 3.8.1.9 requires the verification that each EDG can reject a load of 2500 kW (Unit 3), 2874 kW (Unit 4). ITS SR 3.8.1.13 requires verifying each EDG operates for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> within specified load requirements. These ITS SRs are modified by a Note specifying a power factor limitation if the EDG is synchronized with offsite power. The Note is Note 2 for ITS SRs 3.8.1.8, 3.8.1.9, and SR 3.8.1.13. These Notes state that if the Surveillance is performed with the EDG synchronized with offsite power, it shall be performed at a power factor less than or equal to the power factor of the associated single largest post-accident load or less than or equal to that determined by the diesel loading analysis.

However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. This changes the CTS requirement by specifying a power factor if the testing is conducted when synchronized with offsite power.

The addition of this Note is acceptable because the testing should be conducted as close as possible to the conditions that would be experienced by an EDG following an accident. Loading the EDG solely with the inductive characteristics of a large motor will create a power factor less than unity. The design of the EDG is set for full power operation with a power factor of 0.8. Therefore, testing of the EDG for a loss of the single largest load and at full load is acceptable with a power factor specified. This change is designated as more restrictive because the testing required by the CTS does not currently contain these limitations.

M05 CTS 4.8.1.1.2.g.5, the Engineered Safety Feature (ESF) actuation test (without a loss of power), requires the EDG to start within 15 seconds and operate on standby for greater than or equal to 5 minutes maintaining frequency and voltage within specifications. ITS SR 3.8.1.11 requires the verification that each EDG auto-starts from a standby condition, that permanently connected loads remain energized from the offsite power system, and that emergency loads are auto-Turkey Point Unit 3 and Unit 4 Page 9 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING connected through the time delay relays, where applicable, from the offsite power system. This changes the CTS by adding additional performance requirements for the ESF actuation test (without a loss of power).

The purpose of the CTS 4.8.1.1.2.g.5 is to test the performance of each EDG when an ESF actuation test (without a loss of power) signal is simulated. The proposed change adds an additional requirement that verifies the appropriate loads are connected to the offsite circuit. The change is acceptable because the acceptance criteria are consistent with the design requirements of the EDGs and with other similar SRs where the EDG starts and ties to the emergency buses.

This change is designated as more restrictive because additional acceptance criteria have been added to the CTS.

M06 CTS 3.8.1.1.b requires that three separate and independent diesel generators are OPERABLE. The

  • footnote to CTS 3.8.1.1.b states that, "Whenever one or more of the four EDGs is out-of-service, ensure compliance with the EDG requirements specified in Specifications 3.5.2 and 3.8.2.1." ITS LCO 3.8.1.b requires two emergency diesel generators (EDGs) capable of supplying the onsite Class 1E power distribution trains. ITS LCO 3.8.1.d requires the required opposite unit EDG(s) capable of supplying power to support equipment required by LCO 3.5.2, LCO 3.7.10, LCO 3.7.11, and LCO 3.8.4. In addition, the *footnote is not included in the ITS. This changes the CTS by requiring both opposite unit EDGs when both EDGs are needed to support loads required by other Specifications.

The purpose of ITS LCO 3.8.1 is to ensure adequate onsite and offsite AC Sources are available to support required equipment. The explicit requirement for which opposite unit EDGs are required to support the unit electrical loads is not included in CTS 3.8.1.1. However, one or both opposite unit EDGs may be required to support the ECCS, CREVS, CREATCS, and DC Sources based on the AC Electrical Distribution System lineup. CTS LCO 3.5.2 requires, in part, four safety injection (SI) pumps, each capable of being powered from its associated OPERABLE EDG except when the opposite unit is in MODE 4, 5, 6, or defueled. CTS LCO 3.8.2.1 requires all four 125V battery banks and associated battery chargers to be OPERABLE and for each required battery charger, the LCO requires the associated EDG to be OPERABLE. Thus, when the four batteries are aligned to their normal battery chargers, all four EDGs (two unit and two opposite unit EDGs) are required to be OPERABLE. Additionally, to support accident analyses in the event of a design basis accident, loss of offsite power, and the failure of an associated unit Class 1E electrical bus, an opposite unit EDG is required to support CREVS and CREATCS components. Therefore, ITS LCO 3.8.1.d requires the opposite unit EDGs to be OPERABLE to support the requirements of LCO 3.5.2, 3.7.10, 3.7.11, and 3.8.4. This presentation of the LCO is consistent with the presentation at other sites that utilize shared systems: For example: Catawba Nuclear Station Units 1 and 2 Technical Specifications, LCO 3.8.1, AC Sources - Operating, (NRC ADAMS Accession No. ML052990150), Edwin I. Hatch Nuclear Plant Unit 1 Technical Specifications, LCO 3.8.1, AC Sources - Operating, (NRC ADAMS Accession No. ML052930172), and Donald C. Cook Nuclear Plant Unit 1 Technical Specifications, LCO 3.8.1, AC Sources - Operating, (NRC ADAMS Accession Turkey Point Unit 3 and Unit 4 Page 10 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING No. ML053050305). This change is designated as more restrictive because additional LCO requirements are being applied in the ITS than were applied in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.1.a requires two startup transformers and the associated circuits to be OPERABLE. CTS Actions and SRs identify 1) startup transformers and/or the/its associated circuits, and 2) startup transformer(s).

ITS LCO 3.8.1 requires two qualified circuits between the offsite network and the onsite Class 1E AC Electrical Distribution System, and ITS Actions and SRs label these circuits offsite circuits. This changes the CTS by moving the details that the offsite circuits are "independent" or "physically independent," and that the offsite circuits contain startup transformers and associated circuits from the CTS to the Technical Specification Bases.

The removal of these details related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement for OPERABLE offsite sources. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.1.b requires three "separate and independent" EDG sets to be OPERABLE. ITS LCO 3.8.1 requires EDGs capable of supplying the onsite Class 1E AC Electrical Distribution System. This changes the CTS by moving the details that the EDGs are "separate and independent," from the CTS to the Bases.

The removal of these details related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement for OPERABLE EDGs.

Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of Turkey Point Unit 3 and Unit 4 Page 11 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING detail change, because information relating to system design is being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.1.b requires three separate and independent diesel generators to be OPERABLE and includes specific supporting requirements.

CTS 3.8.1.1.b.1.f and 3.8.1.1.b.2.d require specific motor control center (MCC) buses to be energized for specific EDGs. ITS LCO 3.8.1 does not include a discussion regarding MCCs energized for specific EDGs. This changes the CTS by moving the design details regarding MCCs for specific EDGs from the CTS to the Bases.

The purpose of the CTS requirement is to ensure power is supplied to the MCCs associated with the EDGs auxiliaries. The removal of these details related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement for OPERABLE EDGs. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA04 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.1, ACTION b.2 and ACTION c.2, state, in part, that if the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, to demonstrate the OPERABILITY of the remaining required EDGs by performing SR 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In addition, CTS 3.8.1, ACTION c.2, states, in part, to demonstrate the OPERABILITY of the remaining required EDGs by performing SR 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> unless the EDGs are already operating. ITS 3.8.1, Required Action C.3.1, states to determine OPERABLE EDG(s) is not inoperable due to R2 common cause failure. This changes the CTS by removing the details of what is not a potential common mode failure.

The removal of these details for performing actions from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirement to ensure the absence of any potential common mode failure for the remaining EDGs is determined.

Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

Turkey Point Unit 3 and Unit 4 Page 12 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING LA05 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS SR 4.8.1.1.2.a.4 states, in part, that the EDG shall be started for this test by using one of the following signals: a) Manual, b) Simulated loss-of-offsite power by itself, c) Simulated loss-of-offsite power in conjunction with an ESF Actuation test signal, or d) An ESF Actuation test signal by itself. ITS SR 3.8.1.6 does not include this information associated with the specific test signal that must be used to start this test. This changes the CTS by removing the details of the specific test signal that must be used to start this test.

The removal of these details for performing actions from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA06 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS SR 4.8.1.1.2.a.4 states, in part, that the EDG shall be synchronized loaded for Unit 3 until automatic transfer of fuel from the day tank to the skid mounted tank is demonstrated, and the cooling system is demonstrated OPERABLE. ITS SR 3.8.1.2 does not include this information associated with the specific test acceptance requirements. This changes the CTS by removing the details of the specific test acceptance requirements.

The removal of these details for test acceptance requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA07 Not Used.

LA08 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS SR 4.8.1.1.2.g.2 requires verification of each EDG's capability to reject a load of greater than or equal to 392 kW while maintaining voltage and frequency within specified ranges. ITS SR 3.8.1.8 requires a similar verification but does not specify the value of the single largest post-accident load to reject. This changes the CTS by moving the detail of the single largest load to the ITS Bases.

The removal of these details related to system design from the Technical Specifications is acceptable because this type of information is not necessary to Turkey Point Unit 3 and Unit 4 Page 13 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement to verify that each EDG can maintain voltage and frequency within specified ranges upon rejection of the single largest post-accident load. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA09 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) SR CTS 4.8.1.1.2.g states that each EDG shall be demonstrated OPERABLE by verifying that the fuel transfer pump transfers fuel from the fuel storage tank (Unit 3), fuel storage tanks (Unit 4) to the day tanks of each diesel associated with the unit via the installed cross-connection lines.

ITS 3.8.1 does not include this SR. This changes the CTS by the removal of this SR and placing it in the Technical Requirements Manual (TRM).

The removal of requirement to verify that the opposite trains EDG fuel transfer pump has the ability to supply the EDG fuel oil day tanks from the Technical Specifications is acceptable because this test is not necessary to be included in the Technical Specifications in order to demonstrate OPERABILITY of an EDG.

The ITS retains the requirement to ensure fuel oil can be transferred from the fuel oil storage tank(s) to the EDGs by the use of its train specific fuel oil transfer pump. Also, this change is acceptable because these details will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a surveillance requirement is being removed from the Technical Specifications.

LA10 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.1.1.b.1.a states, in part, that an OPERABLE EDG includes a separate skid-mounted fuel tank and a separate day fuel tank with an OPERABLE solenoid valve to permit gravity flow from the day tank to the skid mounted tank. ITS SR 3.8.1.3 requires verification that each EDG has the following fuel oil volume: a) Unit 3 EDGs day tank and skid tank contains 2000 gallons of fuel oil, and b) Unit 4 EDGs day tank contains 230 gallons of fuel oil. This changes the CTS by not including the procedural details that the Unit 3 EDG fuel oil requirement includes an OPERABLE solenoid valve to permit gravity draining of fuel oil from the day tank to the skid tank.

The removal of these details for performing surveillance requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for a separate skid-mounted fuel tank and a separate day fuel tank with the two tanks together containing a minimum of 2000 gallons of fuel oil. Also, this change is acceptable because these types of procedural details will be adequately Turkey Point Unit 3 and Unit 4 Page 14 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.8.1.1 Action a provides R2 actions when the unit startup transformer or associated circuit is inoperable.

CTS Actions a.3 and a.5 provide different actions based on the unit's MODE. If the inoperability is associated with the unit's circuit and the unit is in MODE 1 CTS allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the inoperable circuit or in accordance with the Risk Informed Completion Time Program. If the inoperability is associated with the unit's circuit and the unit is in MODE 2, 3, or 4, CTS allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the inoperable circuit or in accordance with the Risk Informed Completion Time Program. ITS 3.8.1 provides one ACTION for an inoperable circuit if it is associated with the unit and is not dependent on the applicable operational MODE. ITS 3.8.1 Required Action A.3 requires that with one unit offsite circuit inoperable to restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program.

This changes the baseline Completion Time in the CTS actions for an inoperable unit's startup transformer and associated circuit when in MODE 2, 3, or 4 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The purpose of Actions with an offsite circuit is inoperable is to limit the time the unit can operate with an inoperable AC Source and to perform other compensatory measures. The Required Actions are used to establish remedial measures that must be taken in response to degraded conditions in order to minimize risk associated with continued plant operation while providing time to repair inoperable equipment. The ITS Required Actions are consistent with safe operation under the specified Condition, considering the capacity and capability of the remaining AC sources, a reasonable time for repairs or replacement of required equipment, and the low probability of a design basis accident occurring during the time period. The change is also acceptable because the proposed Completion Time is consistent with the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time currently allowed when a startup transformer or an associated circuit is inoperable for the associated unit when in MODE 1 without a power reduction. Operation in MODES 2, 3, and 4 typically represents less risk than operation in MODE 1. Therefore, it is reasonable that limiting operation in MODE 2, 3, or 4 with the unit offsite circuit inoperable to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program is acceptable.

The ITS ACTION for an inoperable unit offsite circuit is consistent with the ISTS and provides acceptable remedial actions pursuant to 10 CFR 50.36(c)(2)(i).

This change is designated as less restrictive because the time to restore required electrical equipment to OPERABLE status in the CTS has been extended in the ITS.

Turkey Point Unit 3 and Unit 4 Page 15 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING L02 (Category 4 - Relaxation of Required Action) CTS 3.8.1, ACTIONs a.3.b, a.4, a.5, b.3, d.1, e.2, and f, in part, require that if the associated Action and Completion Time are not met to be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; or in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. ITS 3.8.1, ACTION H, requires that with the Required Action R2 and associated Completion Time of Condition A, B, C, D, E, F, or G not met to be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.8.1, ACTION I requires R2 that with the Required Action and associated Completion Time of Condition A, B, C, D, E, F, or G not met to be in MODE 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 in 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

This changes the CTS by requiring a less restrictive end state in the required actions, MODE 4 (HOT SHUTDOWN) instead of MODE 5 (COLD SHUTDOWN).

The purpose of the CTS 3.8.1.1 ACTIONS is to limit the time the unit can remain operating with different combinations of inoperable offsite circuits and EDGs. Once these limits to operation are exceeded, ACTION H or I is entered to provide a R2 reasonable time to place the unit is a safe condition. End states are usually defined based on placing the unit into a MODE or condition in which the Technical Specification LCO is not applicable. MODE 5 is the current end state for LCOs that are applicable in MODES 1 through 4. This change is acceptable because the risk of the transition from MODE 1 to MODES 4 or 5 depends on the availability of AC sources and the ability to remove decay heat such that remaining in MODE 4 may be safer. During the realignment from MODE 4 to MODE 5, there is an increased potential for loss of shutdown cooling and loss of inventory events. Decay heat removal following a loss-of-offsite power event in MODE 5 is dependent on AC power for shutdown cooling whereas, in MODE 4, the turbine driven AFW pump will be available. Therefore, transitioning to MODE 5 is not always the appropriate end state from a risk perspective. Thus, for specific TS conditions, Westinghouse Topical Report WCAP-16294-A, Revision 1 (ADAMS Accession No. ML103430249), justifies MODE 4 as an acceptable alternate end state to Mode 5.

The proposed change to the Technical Specifications will allow time to perform short-duration repairs, which currently necessitate exiting the original mode of applicability. The MODE 4 Technical Specification end state is applied, and risk is assessed and managed in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." Modified end states are limited to conditions where: (1) entry into the shutdown mode is for a short interval, (2) entry is initiated by inoperability of a single train of equipment or a restriction on a plant operational parameter, unless otherwise stated in the applicable Technical Specification, and (3) the primary purpose is to correct the initiating condition and return to power operation as soon as is practical. This proposed change is consistent with NRC approved TSTF-432-A, Revision 1 (ADAMS Accession No. ML103360003), noticed for availability by the NRC in the Federal Register (77 FR 27814) on May 11, 2012. The NRC's approval of WCAP-16294-A included four limitations and conditions on its use as identified in Section 4.0 of the NRC Safety Evaluation associated with WCAP-16294-A. Implementation of these stipulations were addressed in the Bases of TSTF-432-A. Florida Power & Light implemented these limitations and conditions at PTN in the adoption of the associated TSTF-432-A Bases. This change is designated as less restrictive because less Turkey Point Unit 3 and Unit 4 Page 16 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING stringent Required Actions are being applied in the ITS than were applied in the CTS.

L03 (Category 4 - Relaxation of Required Action) CTS 3.8.1, ACTION b.2, states, in part, that with one of the required EDGs inoperable and testing of remaining required EDGs is required to determine any potential common mode failure for the remaining EDGs, this testing must be performed regardless of when the inoperable EDG is restored to OPERABILITY. ITS 3.8.1, ACTION C, requires a determination that the OPERABLE EDGs are not inoperable due to a common cause failure or similarly performance of a test; however, this test is not required to be performed when the inoperable EDG is restored to OPERABILITY within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This changes the CTS by not requiring a CTS Action to be performed.

The purpose of CTS 3.8.1, ACTION b.2, is to provide assurance that a loss of offsite power, during the period that a EDG is inoperable, does not result in a complete loss of safety function of critical systems while providing an allowance to avoid unnecessary testing of OPERABLE EDG(s). This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a Design Basis Accident (DBA) occurring during the repair period. CTS requires that if testing of remaining required diesel generators is required to determine any potential common mode failure for the remaining EDGs, this testing must be performed regardless of when the inoperable EDG is restored to OPERABILITY.

ITS does not include this requirement but relies on the corrective action program to implement an investigation into the cause(s) of the EDG inoperability including any common cause evaluations. If testing of the OPERABLE EDGs is required to ensure the cause of the inoperable EDG does not render the remaining EDGs inoperable, the corrective action program will direct the test's performance. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L04 (Category 3 - Relaxation of Completion Time) CTS 3.8.1.1, ACTION c.2, specifies the compensatory actions for one inoperable startup transformer and one inoperable EDG. The Actions includes a requirement to demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing SR 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS 3.8.1, Required Action C.3.2, allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform a similar check on the remaining OPERABLE EDGs. This changes the CTS by extending the time to perform this check from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The purpose of the CTS 3.8.1.1, ACTION c.2, requirement to perform CTS SR 4.8.1.1.2.a.4 is to ensure that the other EDGs are not inoperable as a result of a similar, yet undetected, failure (i.e., due to a common mode failure). This change is acceptable because the proposed 24-hour time limit to perform CTS SR 4.8.1.1.2.a.4 when equipment is inoperable is consistent with Generic Letter Turkey Point Unit 3 and Unit 4 Page 17 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING (GL) 84-15,"Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," and has already approved for use by the NRC. CTS 3.8.1.1, ACTION b.2, includes a similar requirement to perform CTS SR 4.8.1.1.2.a.4 when only an EDG is inoperable but allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform the verification.

When both an offsite circuit and an EDG are inoperable, the AC Sources are in a more degraded state. The focus of the operations personnel should be in restoring the inoperable AC Sources not in attempting to perform a routine Surveillance in a shorter amount of time. The proposed 24-hour time limit is considered a reasonable time to complete the EDG start tests on the remaining required EDGs. In addition, the change is considered acceptable since the vast majority of EDG start tests demonstrate that the EDG is OPERABLE. This change is designated as less restrictive because more time will be allowed to complete a Required Action in the ITS than is allowed in the CTS.

L05 (Category 4 - Relaxation of Required Action) CTS SR 4.8.1.1.c.2 provides required actions to demonstrate that OPERABILITY of the remaining EDGs unless it can be confirmed that the cause of the inoperable EDG does not exist on the remaining required EDGs. In addition, CTS 3.8.1.1.c.2 states that if testing of the remaining required EDGs is required, this testing must be performed regardless of when the inoperable EDG is restored to OPERABILITY.

ITS 3.8.1, ACTION C, does not include this requirement to test the remaining required EDGs regardless of when the inoperable EDG is restored to OPERABILITY. This changes the CTS by deleting a requirement to test remaining required EDG once the inoperable EDG is returned to OPERABLE.

The purpose of ITS LCO 3.8.1 is to ensure an AC Source is available to support required equipment. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. In the event the inoperable EDG is restored to OPERABLE status prior to completing either C.3.1 or C.3.2, the station corrective action program will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24-hour constraint imposed while in Condition C. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L06 (Category 4 - Relaxation of Required Action) CTS 3.8.1.1, ACTION d, requires verification that with one EDG inoperable all required systems, subsystems, trains, components, and devices that depend on the remaining required OPERABLE EDGs as a source of emergency power are also OPERABLE.

CTS 3.8.1.1, ACTION d.1, applies to all required systems, subsystems, trains, components and devices except for the SI pumps. CTS 3.8.1.1, ACTION d.2, applies to the SI pumps and allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to verify at least two SI pumps are OPERABLE and capable of being powered from their associated OPERABLE Turkey Point Unit 3 and Unit 4 Page 18 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING EDGs. ITS 3.8.1, Required Action C.2, provides a similar action requiring, with one required EDG inoperable, to declare required feature(s) supported by the inoperable EDG inoperable when its required redundant feature(s) is inoperable within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition C concurrent with inoperability of redundant required feature(s). The ITS ACTIONS do not include specific action associated with the SI pumps. This changes the CTS by deleting a specific action associated with confirming two SI pumps are OPERABLE and capable of being powered from their associated OPERABLE EDGs.

The purpose of ITS LCO 3.8.1 is to ensure an AC source is available to support required equipment. Although ITS 3.8.1, Required Action C.2, does not include specific confirmation requirements for the SI pumps, the Required Action implicitly includes the SI subsystems because the SI subsystems are required features supported by EDGs. ITS LCO 3.5.2 requires, in part, two-unit SI subsystems and one opposite unit SI subsystem to be OPERABLE. Each of the three required SI subsystems are redundant required features, therefore, if a required EDG is inoperable concurrent with an inoperable redundant required SI subsystem action must be taken within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to either: restore the redundant SI subsystem to OPERABLE status, restore the inoperable EDG to OPERABLE status, or declare the SI subsystem, associated with the inoperable EDG, inoperable. Two of three required inoperable SI subsystems will result in entry into LCO 3.0.3 per the ITS 3.5.2 ACTIONS. This action is similar to the resulting action in CTS, which requires a plant shutdown if two of three SI pumps are inoperable or not capable of being powered by their associated EDG. This change is consistent with ISTS ACTIONS and acceptable because ITS retains the requirement to confirm redundant feature(s) of the required feature(s) supported by the inoperable EDG are OPERABLE, which includes the required SI subsystems, and declare the required feature inoperable when its required redundant feature(s) is inoperable. This change is designated less restrictive because specific CTS action are being deleted.

L07 (Category 3 - Relaxation of Completion Time) CTS 3.8.1, ACTION d.1, states, in part, that with one EDG inoperable, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> verify all required systems, subsystems, trains, components, and devices (except SI pumps) that depend on the remaining required OPERABLE EDGs as a source of emergency power are also OPERABLE. ITS 3.8.1, Required Action C.2, states to declare required feature(s) supported by the inoperable EDG inoperable when its required redundant feature(s) is inoperable within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition C concurrent with inoperability of redundant required feature(s). This changes the CTS by allowing two additional hours to restore inoperable AC sources prior to declaring the associated equipment inoperable.

The purpose of CTS 3.8.1, Action d.1, is to ensure adequate power is available to required equipment so that the equipment can perform its safety function(s) during DBAs and transients. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. This change allows more time to restore inoperable Turkey Point Unit 3 and Unit 4 Page 19 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING equipment when required AC Sources are inoperable concurrent with inoperabilities of redundant required features. By declaring the affected supported equipment inoperable, and as a result, taking the Technical Specification ACTIONS of the affected supported equipment, unit operation is maintained within the bounds of the Technical Specifications and approved ACTIONS. Since the AC Sources support the OPERABILITY of the affected equipment, it is appropriate that the proper action, in this condition, would be to declare the affected supported equipment inoperable. However, CTS 3.8.1, ACTION d.1, is overly restrictive, in that if the associated supported equipment were inoperable for other reasons and the redundant equipment was also inoperable, a restoration time is sometimes provided in other CTS sections. The 4-hour Completion Time with one EDG inoperable takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature and is considered to be less of a risk than subjecting the unit to transients associated with shutdown. This change is designated as less restrictive because additional time is allowed to restore equipment to OPERABLE status.

L08 (Category 4 - Relaxation of Required Action) CTS 3.8.1.1, ACTION e.2, states R2 that with two startup transformers or the associated circuits inoperable to restore at least one of the inoperable startup transformers to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />s* and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The footnote associated with the asterisk following "6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />" states that if the opposite unit is shutdown first, this time can be extended to 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />, thus changing the time required to be in HOT STANDBY from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> and the time to be in COLD SHUTDOWN from 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. ITS 3.8.1, ACTION I, reduces the possible 42-hour R2 CTS extension to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and the final end state to MODE 4, changing the time required to be in HOT STANDBY (MODE 3) from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or possibly 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />, to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and the time to be in COLD SHUTDOWN (MODE 5) from 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, or possibly 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, to MODE 4 (HOT SHUTDOWN) in 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. This changes the CTS by requiring a less restrictive end state in the required actions, MODE 4 (HOT SHUTDOWN) instead of MODE 5 (COLD SHUTDOWN) and includes 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to be in MODE 3 instead of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The purpose of CTS 3.8.1.1, ACTION e.2, is to provide the appropriate compensatory actions for two inoperable offsite circuits and requires to be in at least HOT STANDBY within the next 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />s* and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. CTS 3.8.1.1.e.2, Footnote *, states that if the opposite unit is shutdown first, this time can be extended to 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />. The intent of the Footnote, as discussed in PTN License Amendment 138/133 (NRC ADAMS Accession No. ML013380031), is to shut down the units consecutively after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Therefore, the first unit would be in HOT STANDBY (MODE 3) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN (MODE 5) within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, or 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> from MODE 1 to MODE 5. The second unit would commence a shut down after the first unit reached COLD SHUTDOWN (MODE 5). Allowing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for the second unit to be in HOT STANDBY (MODE 3) equates to 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> from the start of the consecutive shut down of both units (36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> plus 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> = 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />. A consecutive shutdown is desired because without the associated units Turkey Point Unit 3 and Unit 4 Page 20 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING startup transformer, a natural circulation cooldown is necessary to reach HOT SHUTDOWN and COLD SHUTDOWN conditions.

ITS 3.8.1, Required Action D.2, provides a similar 24-hour restoration time when two offsite circuits are inoperable to restore one offsite circuit to OPERABLE status. If the Required Action and Completion Time requirements of ITS ACTION D are not met, ACTION H is entered requiring the unit to be in MODE 3 R2 (HOT STANDBY) in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 (HOT SHUTDOWN) in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when a dual unit shutdown is not required consistent with the ISTS. Alternately, if the Required Actions and associated Completion Times of ACTION D are not met and a dual unit shutdown is required ACTION I is entered. ITS 3.8.1, ACTION I, R2 provides additional time to allow a consecutive unit shutdown in the event a natural circulation cooldown is required on both units. ITS 3.8.1, ACTION I, R2 would require the first unit to be in HOT STANDBY (MODE 3) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of entering the shutdown requirement. After 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> the first unit would commence a natural circulation cool down to be in HOT SHUTDOWN (MODE 4) in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while the second unit would commence a shutdown to be in HOT STANDBY (MODE 3) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and HOT SHUTDOWN (MODE 4) within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

This change is acceptable because only one unit will be in a natural circulation shutdown at a time. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L09 (Category 4 - Relaxation of Required Action) CTS 3.8.1.1, ACTION f, states, in part, that with two of the above required EDGs inoperable to restore at least one of the inoperable EDGs to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ITS 3.8.1, ACTION F, states that with two or more required EDGs inoperable, to restore all R2 but one required EDG to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This changes the CTS by allowing continued operation with more than two inoperable EDGs, preventing premature entry into LCO 3.0.3.

The purpose of CTS 3.8.1.1, ACTION f, is to provide appropriate remedial actions when the LCO is not met consistent with the requirements of 10 CFR 50.36(c)(2)(i). This change is acceptable because the Conditions and Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of offsite circuits, a reasonable time for repairs or replacement, and the low probability of a DBA R2 occurring during the repair period. The intent of ISTS 3.8.1, ACTION E, is to allow continued operation for a short period of time with no onsite standby AC sources (i.e., no EDGs). Since the offsite electrical power system is the only source of AC power for this level of degradation, the risk associated with continued operation for a short time could be less than that associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC power). Since any inadvertent generator trip could also result in a total loss of offsite AC power, the time allowed for continued operation with two EDGs inoperable in ISTS 3.8.1 R2 Turkey Point Unit 3 and Unit 4 Page 21 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING ACTION E is severely restricted. The intent is to avoid the risk associated with R2 an immediate controlled shutdown and to minimize the risk associated with this level of degradation. The Completion Time of ISTS 3.8.1 Required Action E.1 of R2 two hours is consistent with the time for this level of degradation specified in NRC Regulatory Guide (RG) 1.93, "Periodic Testing of Diesel Generator Units used as Onsite Electric Power Systems at Nuclear Power Plants." The PTN shared electrical distribution system design requires specific opposite unit EDGs to be OPERABLE to support ECCS, CREVS, CREATCS, and required 125 V DC battery chargers. The purpose of ITS 3.8.1, ACTION F, is to provide actions for the condition where there may be no remaining standby AC sources consistent R2 with the intent of ISTS 3.8.1 ACTION E. Thus, with an assumed loss of offsite electrical power, insufficient standby AC sources may be available to power the minimum required ESF functions. At PTN the condition of more than two required EDGs does not result in a worse level of degradation as in ISTS (i.e.,

loss of all onsite standby AC sources). Therefore, ITS 3.8.1, ACTION F, allows two or more required EDGs to be inoperable and the Required Action requires R2 restoration of all but one EDG to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. These changes continue to meet the intent of the ISTS requirement of continuing operation for a short period of time with no onsite standby AC sources and are made to align the PTN Technical Specifications, as reasonably practical, with the ISTS. Refer to Edwin I Hatch Nuclear Power Plant ITS 3.8.1, Conditions F and I R2 (NRC ADAMS Accession No. ML052930172), for an example of this alternate ITS presentation which has been previously approved and determined acceptable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L10 (Category 8 - Deletion of Surveillance Requirement Shutdown Performance R2 Requirements) CTS SR 4.8.1.1.1.b contains a requirement to manually transfer unit power supply from the auxiliary transformer to the startup transformer "while shutting down." This test has been incorporated in ITS SR 3.8.1.7. ITS SR 3.8.1.7 does not specify conduct of the test to occur while shutting down.

This changes the CTS by deleting the requirement to perform the Surveillance while shutting down.

The purpose of CTS SR 4.8.1.1.1.b is to confirm the OPERABILITY of the offsite circuits. This change is acceptable because the proposed Surveillance Frequency provides an acceptable level of equipment reliability. The proposed Surveillance does not limit the performance of this SR to only while the unit is shutting down. The control of unit conditions appropriate to perform the test is an issue for procedures and scheduling and has been determined by the NRC Staff to be unnecessary as a Technical Specification restriction. As indicated in Generic Letter 91-04, removal of this specific restriction is consistent with the vast majority of other Technical Specification Surveillances that do not dictate unit conditions for the Surveillance. This change is designated as less restrictive because the Surveillance may be performed during plant conditions other than while shutting down.

L11 (Category 7 - Relaxation of Surveillance Frequency) CTS SR 4.8.1.1.2.c requires the removal of accumulated water from the day tank and skid-mounted fuel tanks (Unit 4-day tank only) in accordance with the Surveillance Frequency Turkey Point Unit 3 and Unit 4 Page 22 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING Control Program (SFCP) "and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />." ITS SR 3.8.1.4, which requires the same Surveillance to be performed, does not include the conditional Frequency. This changes the CTS by deleting the requirement to check for and remove accumulated water after each occasion when the EDG is operated for an hour or more.

The purpose of CTS SR 4.8.1.1.2.c is to provide a degree of assurance that the day tanks and Unit 3 skid mounted tanks are free of accumulated water. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability.

Water condensation within the fuel oil day tanks or Unit 3 skid mounted tanks is a time dependent process, not a process dependent on the transfer of fuel oil during EDG operation. Because it is the expectation that the EDG will not be operated and that the fuel oil storage tanks are also periodically checked for water, no increased Frequency is necessary. This change is designated as less restrictive because the explicit requirement to remove accumulated water in the day tank and Unit 3 skid mounted tank after an EDG run of greater than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> has been deleted.

L12 (Category 8 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS SR 4.8.1.1.2.g contains requirements to perform various tests "during shutdown." These tests have been incorporated into ITS SR 3.8.1.8, SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.15, SR 3.8.1.16, SR 3.8.1.17, and SR 3.8.1.18 in Notes. ITS SR 3.8.1.10, SR 3.8.1.15, SR 3.8.1.16, SR 3.8.1.17, and SR 3.8.1.18 Notes state that the Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. ITS SR 3.8.1.8, SR 3.8.1.9, SR 3.8.1.11, and SR 3.8.1.12 Notes state that the Surveillance shall not normally be performed in MODE 1 or 2. The Notes also state that portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced, further stating that credit may be taken for unplanned events that satisfy this SR. Additionally, a clarifying statement from CTS is added to the ITS Notes stating that these MODE restrictions are applicable only to the two EDGs associated with the unit. This changes the CTS by replacing the requirement to perform the Surveillances during shutdown (MODES 4, 5, 6, or Defueled) with a Note stating when the Surveillances are not normally performed (either MODES 1 or 2; or MODES 1, 2, 3, or 4) and allowing the test to be performed in these MODES as long as the associated assessment is performed or provided that an unplanned event satisfies the requirements of the Surveillance.

The purpose of CTS SR 4.8.1.1.2.g is to confirm the OPERABILITY of each EDG. This change is acceptable, because the Surveillances, as modified by the revised Note, have been evaluated to ensure they provide an acceptable level of equipment reliability. The proposed Surveillances do not include the restriction that limits performance of the SR only when shutdown. It allows the unit to perform the Surveillances to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced and it allows the unit to credit an unplanned event for satisfying the Surveillances, provided the Turkey Point Unit 3 and Unit 4 Page 23 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING necessary data is obtained. Furthermore, the proposed Surveillance Note still restricts planned performance of the Surveillances to MODES other than MODE 1 or 2, or MODE 1, 2, 3, or 4, as applicable. The control of the unit conditions appropriate to perform the tests is an issue for procedures and scheduling and has been determined by the NRC Staff to be unnecessary as a Technical Specification restriction. As indicated in GL 91-04, allowing this control is consistent with most of the other Technical Specification Surveillances that do not dictate unit conditions for the Surveillance. This change is designated as less restrictive because the Surveillances may be performed during plant conditions other than shutdown.

L13 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria) CTS SR 4.8.1.1.2.g.4 requires verification of EDG performance following a "simulated" loss of offsite power. CTS SR 4.8.1.1.2.g.5 requires verification of EDG performance following an ESF actuation "test" signal. CTS SR 4.8.1.1.2.g.6.a, b, and c require verification of EDG performance following a "simulated" loss of offsite power in conjunction with an ESF actuation "test" signal. CTS SR 4.8.1.1.2.g.10 requires verification of EDG test mode override following a simulated SI signal. ITS SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.16, and SR 3.8.1.18 specify that the signal may be either an "actual or simulated" signal.

This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.

The purpose of CTS SR 4.8.1.1.2.g.2, CTS SR 4.8.1.1.2.g.5, and CTS SR 4.8.1.1.2.d.6 is to ensure that the AC Sources operate correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed SR acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its specified safety functions. Equipment cannot discriminate between an "actual,"

"simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.

L14 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS SR 4.8.1.1.2.g.7 requires verification that each EDG can operate for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, with loading at the 2-hour rating during the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and at a load equivalent of the continuous duty rating during the remaining hours of the test.

The CTS further requires that the generator voltage and frequency shall be 3950-4350 volts and 60 +/- 0.6 Hz within 15 seconds after the start signal and that the steady-state generator voltage and frequency shall be maintained within these limits during this test. ITS SR 3.8.1.13 requires a similar test; however, it does not specify that the generator voltage and frequency shall be 3950-4350 volts and 60 +/- 0.6 Hz within 15 seconds after the start signal. This changes the CTS by removing the timed voltage and frequency limits for the initial start of the EDG.

The purpose of CTS SR 4.8.1.1.2.g.7 is to verify the capability of each EDG to run continuously at full load for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. EDG operation with voltage and frequency within the specified limits will continue to be verified during Turkey Point Unit 3 and Unit 4 Page 24 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING performance of ITS SR 3.8.1.6, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.14, SR 3.8.1.18, and SR 3.8.1.19. This change is acceptable because it has been determined that the relaxed SR acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its specified safety functions. The Surveillance will continue to verify that the EDG is capable of running continuously at full load for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of which is at the 2-hour rating, consistent with the loading position of RG 1.108, "Periodic Testing of Diesel Generator Units used as Onsite Electric Power Systems at Nuclear Power Plants," Regulatory Position C.2.a.(3). This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.

L15 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS SR 4.8.1.1.2.g.7 states, in part, that within 5 minutes after completing the 24-hour test to verify the EDG starts and accelerates to reach a generator voltage and frequency of 3950-4350 volts and 60 +/- 0.6 Hz within 15 seconds after the start signal.** Footnote ** modifies this requirement by stating that if verification of the EDGs ability to restart and accelerate to a generator voltage and frequency of 3950-4350 volts and 60 +/- 0.6 Hz within 15 seconds following the 24-hour operation test of CTS SR 4.8.1.1.2.g.7 is not satisfactorily completed, it is not necessary to repeat the 24-hour test. Instead, the EDG may be operated between 2300-2500 kW Unit 3, (2650-2850 kW Unit 4) for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until operating temperature has stabilized (whichever is greater). ITS SR 3.8.1.14 similarly requires verification that each EDG starts and achieves within 15 seconds voltage 3950 volts and frequency 59.4 Hz and a steady state voltage 3950 volts and 4350 volts with a frequency 59.4 Hz and 60.6.

This SR is modified by a Note stating that this Surveillance shall be performed within 5 minutes of shutting down the EDG after the EDG has operated for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded. This changes the CTS by not requiring the performance of the 24-hour test but only a 2-hour loaded pre-test EDG operation prior to verifying the EDG's ability to start within 15 seconds.

The purpose of CTS SR 4.8.1.1.2.g.7 is to demonstrates that the diesel engine can restart from a hot condition, such as after shutdown from normal Surveillances, and achieve the required voltage and frequency within 15 seconds. This change is acceptable because it has been determined that the relaxed SR acceptance criteria of after a 24-hour loaded operation is not necessary for verification that the equipment used to meet the LCO can perform its required functions. Operating the EDG for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded provides adequate warm up period to determine if the EDG is capable for restating. This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.

L16 (Category 5 - Deletion of Surveillance Requirement) CTS SR 4.8.1.1.2.g.8 requires verification that the auto-connected loads to each EDG do not exceed 2500 kW (Unit 3), 2874 kW (Unit 4). ITS 3.8.1 does not require the verification of this loading limit to ensure OPERABILITY of the EDGs. This changes the CTS by deleting the SR.

This change is acceptable because the deleted SR is not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, Turkey Point Unit 3 and Unit 4 Page 25 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its specified safety function. Each EDG will continue to be tested in a manner to ensure the safety analyses assumption will be met. Changes to the auto-connected loads will be controlled and evaluated by the design change control process to ensure the EDG is not overloaded. This change is designated as less restrictive because a Surveillance which is required in the CTS will not be required in the ITS.

L17 (Category 5 - Deletion of Surveillance Requirement) CTS SR 4.8.1.1.2.g.13 requires verifying that the EDG lockout relay prevents the EDG from starting.

ITS 3.8.1 Surveillances do not include this SR. This changes the CTS by deleting the SR to verify that the EDG lockout relay prevents the EDG from starting.

The purpose of CTS SR 4.8.1.1.2.g.13 is to provide greater confidence that the EDGs will operate, as designed. This change is acceptable because the deleted SR is not necessary to verify that the EDGs used to meet the LCO can perform the specified safety functions. The EDG surveillances included in ITS 3.8.1 ensures the EDGs will continue to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its specified safety function. The function of the EDGs is that with any credible single failure, the EDGs are capable of assuring a safe shut down of both units with a loss of offsite power concurrent with Maximum Hypothetical Accident (MHA) conditions in one unit. The purpose of the lockout relay is to prevent the EDG from starting or shutting the EDG down to prevent or minimize the damage the EDG. Because this surveillance is to minimize the damage to the EDG and not to ensure the EDG can perform its specified safety function, removal of this SR is acceptable.

This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L18 (Category 5 - Deletion of Surveillance Requirement) CTS SR 4.8.1.1.2.h requires verification that the EDGs achieve the specified voltage and frequency within 15 seconds when started simultaneously in accordance with the SFCP or after any modifications which could affect EDG interdependence.

ITS SR 3.8.1.19 does not include the requirement to test simultaneous start of the EDGs after any modifications which could affect EDG interdependence. This changes the CTS by deleting the requirement to simultaneously start the EDGs after any modifications which could affect EDG interdependence.

This change is acceptable because the deleted SR is not necessary to verify that the equipment used to meet the LCO is consistent with the safety analyses.

Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected. Following repair, maintenance, modification, or replacement of a component that may affect OPERABILITY, post maintenance testing is required to demonstrate OPERABILITY of the system or component.

This is described in the Bases of ITS SR 3.0.1 and required under SR 3.0.1. The OPERABILITY requirements of the EDGs are described in the Bases for Specification 3.8.1. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control) provide adequate controls for test programs to ensure Turkey Point Unit 3 and Unit 4 Page 26 of 27

DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING that testing incorporates applicable acceptance criteria. Compliance with 10 CFR 50 is required under the units operating license. As a result, post maintenance testing will continue to be performed and an explicit requirement in the Technical Specifications is not necessary. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L19 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria) CTS SR 4.8.1.1.2.g.5, CTS SR 4.8.1.1.2.g.7, and CTS SR 4.8.1.1.2.h require, in part, that when starting the EDG the generator voltage and frequency be 3950-4350 volts and 60 +/- 0.6 Hz within 15 seconds after the start signal. ITS SR 3.8.1.11, ITS SR 3.8.1.14, and ITS SR 3.8.1.19, in part, requires verification that each EDG starts from standby conditions and achieves a voltage of 3950 V and frequency 59.4 Hz within 15 seconds and requires a steady state voltage and frequency of 3950 V and 4350 V and 59.4 Hz and 60.6 Hz. This changes CTS by replacing the voltage and frequency band requirement during the starting of an EDG with minimum values until steady state conditions are reached.

A purpose of the CTS SR 4.8.1.1.2.g.5, CTS SR 4.8.1.1.2.g.7, and CTS SR 4.8.1.1.2.h is to test for the ability of each EDG to start and be ready for loading within a prescribed period. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria (i.e., upper voltage and frequency limits) within 15 seconds are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by specifying a minimum voltage and frequency limit to be achieved within 15 seconds instead of a voltage and frequency range. This removes the upper voltage and frequency limits during EDG acceleration, however, keeping upper voltage and frequency limits during steady state operation. The accident analyses requires that the EDGs be capable of being loaded within 15 seconds. This can be accomplished at the lowest level in the frequency and voltage ranges. Verification that the minimum voltage and frequency limits are met within the proper time is sufficient to ensure the EDG can perform its design function. Once the minimum voltage and frequency limits are met, the EDG can connect to the bus. When a test is performed that does not result in connecting the EDG to the bus, a voltage or frequency overshoot can occur because no loads are connected (loading tends to minimize overshoot). This overshoot could be such that the voltage or frequency is outside the band high when the time limit expires. However, this condition is not indicative of an inoperable EDG, provided that steady state voltage and frequency are maintained. The EDG start times are monitored and trend evaluated to identify degradation of EDG governor and voltage regulator performance as described in the ITS Bases. This change is designated as less restrictive because less stringent Surveillance test criteria are being applied in the ITS than were applied in the CTS.

Turkey Point Unit 3 and Unit 4 Page 27 of 27

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating 3.8.1.1 LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

3.8.1.1.a DOC A02

a. Two qualified circuits between the offsite transmission network and unit DOC LA01 the onsite Class 1E AC Electrical Power Distribution System, unit emergency EDGs 3.8.1.1.b b. Two diesel generators (DGs) capable of supplying the onsite 1 DOC M06 Class 1E power distribution subsystem(s), and e INSERT 1 DOC A03 [ c. Automatic load sequencers for Train A and Train B. ] 2 Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

NOTE-----------------------------------------------------------

E Actions Note LCO 3.0.4.b is not applicable to DGs. 1 CONDITION REQUIRED ACTION COMPLETION TIME unit Action a. A. One [required] offsite A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 2 Action a.1 circuit inoperable. [required] OPERABLE Action c.1 offsite circuit. AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND Action a.2.

A.2 Declare required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from with no offsite power discovery of no offsite available inoperable when power to one train its redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-1 Rev. 5.0 1

CTS ITS 3.8.1 6

1 INSERT 1 3.8.1.1.a c. One qualified circuit between the offsite transmission network and the DOC A02 opposite unit onsite Class 1E AC electrical power distribution train(s) needed to support equipment required by LCO 3.5.2, ECCS -

Operating, LCO 3.7.10, Control Room Emergency Ventilation System (CREVS), LCO 3.7.11, Control Room Emergency Air Temperature Control System (CREATCS)," and LCO 3.8.4, DC Sources - Operating, 3.8.1.1.b d. Required opposite unit EDG(s) capable of supplying power to equipment DOC M06 required by LCO 3.5.2, LCO 3.7.10, LCO 3.7.11, and LCO 3.8.4, and Insert Page 3.8.1-1

CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME Action a.3.b) A.3 Restore [required] offsite 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 2 circuit to OPERABLE status. [OR 2 In accordance with the Risk Informed Completion Time Program] 2 INSERT 2 C C 3 2 Action b. B. One [required] DG B.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Action b.1, inoperable. E [required] offsite circuit(s).

Action f AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter Action d.2 AND C

B.2 Declare required feature(s) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from 3 Action d.1 supported by the inoperable discovery of C E DG inoperable when its Condition B 1 3 required redundant concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND C 3 2 Action b.2, B.3.1 Determine OPERABLE [24] hours Action c.2 E DG(s) is not inoperable due 1 to common cause failure.

OR C 6 Action b.2, B.3.2 Perform SR 3.8.1.2 for [24] hours 3 2 Action c.2 OPERABLE DG(s). 1 E

AND Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-2 Rev. 5.0 1

CTS ITS 3.8.1 1

INSERT 2 Action a.1 B. One required opposite B.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> unit offsite circuit required OPERABLE offsite inoperable. circuits. AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND Action a.2 B.2 Declare required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from with no offsite power discovery of no offsite available inoperable when power to one train its redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND Action a.4 B.3 Restore required opposite 30 days unit offsite circuit to OPERABLE status.

Insert Page 3.8.1-2

CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C E 14 days 3

Action b.3, B.4 Restore [required] DG to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 2 1 Action f. OPERABLE status.

[OR 2 In accordance with the Risk Informed Completion Time Program] 2 D unit D C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from 3 2 circuits inoperable. inoperable when its discovery of Action e. D 2 OR redundant required Condition C Action e.1 feature(s) is inoperable. concurrent with Three offsite circuits inoperable. inoperability of redundant required features AND D unit C.2 Restore one [required] 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 3 2 offsite circuit to OPERABLE 2

Action e.2 status. [OR In accordance with the Risk Informed Completion Time Program] 2 E or two DOC A13 D. One [required] offsite --------------------NOTE------------------- 3 R2 7

circuit inoperable. Enter applicable Conditions and Action c. s Required Actions of LCO 3.8.9, 2 AND "Distribution Systems - Operating," E E when Condition D is entered with no 3 One [required] DG AC power source to any train. 1 R2 inoperable. ------------------------------------------------

E 72 D.1 Restore [required] offsite 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 3 2 1 circuit to OPERABLE 7 2

R2 status. (s) [OR OR In accordance with the Risk Informed Completion Time Program] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-3 Rev. 5.0 1

CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E E 72 3 2 1 D.2 Restore [required] DG to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action c.3, Action b.3 footnote **

OPERABLE status.

[OR 2 In accordance with the Risk Informed Completion Time Program] 2 F or more E F all but E Action f 7 3 2 1 R2 DOC L09 E. Two [required] DGs E.1 Restore one [required] DG 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> inoperable. to OPERABLE status.

R2 G 72 R2

REVIEWERS NOTE----- F.1 Restore [required] [12] hours 3 2

This Condition may be [automatic load sequencer]

deleted if the unit design is to OPERABLE status. [OR such that any sequencer failure mode will only affect In accordance with 4 the ability of the associated the Risk Informed DG to power its respective Completion Time safety loads following a loss Program] ] 2 of offsite power independent of, or coincident with, a Design Basis Event.

G 3 R2 DOC A06 F. [One [required] 2

[automatic load sequencer] inoperable.

H INSERT 3 H R2 Action a.3.b), 3 G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action a.5, Action b.3, associated Completion Action d.1, Time of Condition A, B, AND Action d.2, Action e.2, C, D, E, or [F] not met. H 3 R2 Action f F, or G G.2 --------------NOTE--------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> INSERT 4 R2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-4 Rev. 5.0 1

CTS ITS 3.8.1 1

INSERT 3 R2

NOTE----------------

Action a.3 Not applicable when a dual Action b.3 Action d.1 unit shutdown is required.

Action e.2 ----------------------------------------

1 INSERT 4 R2 Action a.4, I. -----------NOTES------------ I.1 Be in MODE 3 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> R2 Action e.2 Only applicable when a Action e.3 DOC L08 dual unit shutdown is AND DOC A08 required.

I.2 ----------------NOTE---------------- R2 Required Action and LCO 3.0.4.a is not applicable Associated Completion when entering MODE4.

Time of Condition A, B, ----------------------------------------

C, D, E, F, or G not met. R2 Be in MODE 4. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> Insert Page 3.8.1-4

One required EDG inoperable and two unit offsite circuits inoperable.

OR 7 R2 CTS One required EDG inoperable and three offsite circuits inoperable. AC Sources - Operating OR 3.8.1 Two or more required EDGs inoperable and one or more required offsite circuits inoperable.

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME J J DOC A07 H. Three or more [required] H.1 Enter LCO 3.0.3. Immediately 3 1 2 R2 AC sources inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.1.1a SR 3.8.1.1 Verify correct breaker alignment and indicated [ 7 days 2 power availability for each [required] offsite circuit.

OR In accordance with the Surveillance Frequency Control Program ] 2 SR 3.8.1.2 ------------------------------NOTES-----------------------------

1. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

[ 2. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met. ]

1 Verify each DG starts from standby conditions and [ 31 days achieves steady state voltage [3740] V and

[4580] V, and frequency [58.8] Hz and OR

[61.2] Hz.

In accordance with the Surveillance Frequency Control Program ]

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-5 Rev. 5.0 1

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 2 3 4.8.1.1.2a.5) SR 3.8.1.3 ------------------------------NOTES-----------------------------

E 1 4.8.1.1.2a.4), 1. DG loadings may include gradual loading as 4.8.1.1.2a.5)** recommended by the manufacturer.

4.8.1.1.2a.5)*** 2. Momentary transients outside the load range do not invalidate this test.

DOC M02 3. This Surveillance shall be conducted on only 1

one DG at a time.

E DOC M03

4. This SR shall be preceded by and immediately follow without shutdown a successful 6 performance of SR 3.8.1.2 or SR 3.8.1.7. 3 E

1 Verify each DG is synchronized and loaded and [ 31 days 2

operates for 60 minutes at a load [4500] kW and

[5000] kW. 2300 OR 2500 (Unit 3), 2650 kW and 2850 kW (Unit 4)

In accordance with the Surveillance Frequency Control Program ] 2 3.8.1.1.b.1).a) 3 3.8.1.1.b.2).a) SR 3.8.1.4 Verify each day tank [and engine mounted tank] [ 31 days 3 1 4.8.1.1.2.a.1) contains [220] gal of fuel oil. 2 INSERT 5 OR R2 In accordance with the Surveillance Frequency Control Program ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-6 Rev. 5.0 1

CTS ITS 3.8.1 1

INSERT 5 R2 Verify each EDG has the following fuel oil volume:

3.8.1.1.b.1).a) a) Unit 3 EDGs day tank and skid tank contains 2000 gallons of fuel oil.

3.8.1.1.b.2).a) 4.8.1.1.2.a.1) b) Unit 4 EDGs day tank contains 230 gallons of fuel oil.

Insert Page 3.8.1-6

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4

4.8.1.1.2c SR 3.8.1.5 Check for and remove accumulated water from each [ [31] days 3 day tank [and engine mounted tank]. 2 Unit 3 skid-mounted tank OR In accordance with the Surveillance Frequency Control Program ] 2 5 INSERT 6 R2 3.8.1.1.b.1)c),

3.8.1.1.b.2)c)

SR 3.8.1.6 the Verify the fuel oil transfer system operates to [ [92] days 3 4.8.1.1.2b, [automatically] transfer fuel oil from storage tank[s] 2 4.8.1.1.2g.11) to the day tank [and engine mounted tank]. OR In accordance with the Surveillance Frequency Control Program ] 2 6 3 4.8.1.1.2a.4) SR 3.8.1.7 ------------------------------NOTE-------------------------------

E 1 All DG starts may be preceded by an engine prelube 4.8.1.1.2* period.

E Verify each DG starts from standby condition and [ 184 days 1 achieves:

15 OR

a. In [10] seconds, voltage [3740] V and frequency 58.8] Hz and In accordance 2 3950 4350 with the
b. Steady state voltage [3740] V and [4580] V, Surveillance and frequency [58.8] Hz and [61.2] Hz. Frequency 59.4 60.6 Control Program ]

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-7 Rev. 5.0 1

CTS ITS 3.8.1 1

INSERT 6 R2

NOTE-----------------------------------------------------------

3.8.1.1.b.1)c), Not required to be met for Unit 3 EDGs during use of a temporary Class III fuel storage system Footnote **

as allowed by LCO 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air."

Insert Page 3.8.1-7

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 7

4.8.1.1.1.b SR 3.8.1.8 ------------------------------NOTE------------------------------- 3

[ This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be DOC L10 performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is 2 maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

auxiliary Verify [automatic [and] manual] transfer of AC power [ [18] months 2 transformer sources from the normal offsite circuit to each 1 2 alternate [required] offsite circuit. OR the startup transformer In accordance with the Surveillance Frequency Control Program ] ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-8 Rev. 5.0 1

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 8 For the unit EDGs, this SR 3.8.1.9 ------------------------------NOTES----------------------------- 3 4.8.1.1.2g.2)

[1. This Surveillance shall not normally be 2 performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish DOC L12 OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

E

2. If performed with the DG synchronized with 1 less than or equal to the offsite power, it shall be performed at a power DOC M04 power factor of the single factor [0.9]. However, if grid conditions do not 2 largest post-accident load permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ] 2 E

Verify each DG rejects a load greater than or equal [ [18] months 1 to its associated single largest post-accident load, and: OR

a. Following load rejection, the frequency is In accordance

[63] Hz, with the 66.25 2 Surveillance

b. Within [3] seconds following load rejection, the Frequency voltage is [3740] V and [4580] V, and Control Program ]

2 3950 4350

c. Within [3] seconds following load rejection, the frequency is [58.8] Hz and [61.2] Hz.

59.4 60.6 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-9 Rev. 5.0 1

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY For the unit EDGs, this 9

4.8.1.1.2g.3)

SR 3.8.1.10 ------------------------------NOTES----------------------------- 3

[ 1. This Surveillance shall not normally be 2 performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish DOC L12 OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

E

2. If performed with DG synchronized with offsite 1 less than or equal to that power, it shall be performed at a power factor determined by the diesel [0.9]. However, if grid conditions do not 2 loading analysis permit, the power factor limit is not required to DOC M04 be met. Under this condition the power factor shall be maintained as close to the limit as practicable. ] 2

3 E

returns to 4784 V Verify each DG does not trip and voltage is [ [18] months 1 within 2 seconds 2 maintained [5000] V during and following a load rejection of [4500] kW and [5000] kW. OR 2500 kW (Unit 3), 2874 kW (Unit 4)

In accordance with the Surveillance Frequency Control Program ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-10 Rev. 5.0 1

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 10 3 4.8.1.1.2g.4) SR 3.8.1.11 ------------------------------NOTES-----------------------------

E

1. All DG starts may be preceded by an engine 1 4.8.1.1.2*

prelube period.

For the unit EDGs, this

2. This Surveillance shall not normally be 1 performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed DOC L12 to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

4.8.1.1.2g ---------------------------------------------------------------------

DOC L13 Verify on an actual or simulated loss of offsite power [ [18] months 2 signal:

OR 2

a. De-energization of emergency buses, In accordance
b. Load shedding from emergency buses, with the E Surveillance
c. DG auto-starts from standby condition and: Frequency 1 Control Program ]
1. Energizes permanently connected loads in [10] seconds, 15
2. Energizes auto-connected shutdown loads through [automatic load sequencer],
3. Maintains steady state voltage 2

[3740] V and [4580] V, 3950 4350

4. Maintains steady state frequency

[58.8] Hz and [61.2] Hz, and 59.4 60.6

5. Supplies permanently connected [and auto-connected] shutdown loads for 5 minutes.

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-11 Rev. 5.0 1

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 11 3 4.8.1.1.2g.5) SR 3. 8.1.12 ------------------------------NOTES-----------------------------

E 2 1

[ 1. All DG starts may be preceded by prelube 4.8.1.1.2*

period.

For the unit EDGs, this

2. This Surveillance shall not normally be 1 performed in MODE 1 or 2. However, portions of the Surveillance may be performed to DOC L12 reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

4.8.1.1.2g ---------------------------------------------------------------------

DOC L13 Verify on an actual or simulated Engineered Safety [ [18] months 2 Feature (ESF) actuation signal each DG auto-starts 1 from standby condition and: E OR 2 15

a. In [10] seconds after auto-start and during In accordance tests, achieves voltage [3740] V and with the frequency [58.8] Hz, 3950 Surveillance 59.4 3950 Frequency 2
b. Achieves steady state voltage [3740] V and Control Program ]

4350

[4580] V and frequency [58.8] Hz and

[61.2] Hz, 59.4 60.6

c. Operates for 5 minutes, DOC M05 d. Permanently connected loads remain energized from the offsite power system, and DOC M05 e. Emergency loads are energized [or auto- 2 connected through the automatic load sequencer] from the offsite power system. 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-12 Rev. 5.0 1

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 12 For the unit EDGs, this 3

4.8.1.1.2g.6)c) SR 3. 8.1.13 ------------------------------NOTE-------------------------------

1

[ This Surveillance shall not normally be performed 2 in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an DOC L12 assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR. ] 2 4.8.1.1.2g ---------------------------------------------------------------------

EDG trips made OPERABLE during the test mode of EDG operation are inoperable Verify each DG's noncritical automatic trips are [ [18] months 1 bypassed on [actual or simulated loss of voltage 2 signal on the emergency bus concurrent with an OR actual or simulated ESF actuation signal].

In accordance with the Surveillance Frequency Control Program ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-13 Rev. 5.0 1

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 13 4.8.1.1.2g.7) SR 3.8.1.14 ------------------------------NOTES----------------------------- 3

1. Momentary transients outside the load and 4.8.1.1.2g.7)** power factor ranges do not invalidate this test.
2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish 4.8.1.1.2g.7)#

OPERABILITY provided an assessment 1 determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

2 E 1

3. If performed with DG synchronized with offsite less than or equal to power, it shall be performed at a power factor that determined by the [0.9]. However, if grid conditions do not 2 diesel loading analysis DOC M04 permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

4.8.1.1.2g ---------------------------------------------------------------------

E 1

Verify each DG operates for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s: [ [18] months

a. For [2] hours loaded [5250] kW and OR

[5500] kW and INSERT 7 R2 In accordance 2

b. For the remaining hours of the test loaded with the

[4500] kW and [5000] kW. Surveillance INSERT 8 Frequency R2 Control Program ]

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-14 Rev. 5.0 1

CTS ITS 3.8.1 1

INSERT 7 R2 4.8.1.1.2.g.7) 2550 kW and 2750 kW (Unit 3), 2950 kW and 3150 kW (Unit 4) 1 INSERT 8 R2 4.8.1.1.2.g.7) 2300 kW and 2500 kW (Unit 3), 2650 kW and 2850 kW (Unit 4)

Insert Page 3.8.1-14

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 14 3

4.8.1.1.2g.7) SR 3.8.1.15 ------------------------------NOTES-----------------------------

1. This Surveillance shall be performed within E 1

5 minutes of shutting down the DG after the DG DOC L15 has operated [2] hours loaded [4500] kW 2 and [5000] kW. INSERT 9 R2 4.8.1.1.2g.7)**

Momentary transients outside of load range do not invalidate this test. 5 pre-test requirement E

4.8.1.1.2* 2. All DG starts may be preceded by an engine 1 prelube period.

4.8.1.1.2g ---------------------------------------------------------------------

E 1 Verify each DG starts and achieves: [ [18] months 15 3950

a. In [10] seconds, voltage [3740] V and OR frequency [58.8] Hz and 59.4 3950 4350 In accordance 2
b. Steady state voltage [3740] V, and [4580] V with the and frequency [58.8] Hz and [61.2] Hz. Surveillance 59.4 60.6 Frequency Control Program ]

For the unit EDGs, this 15 4.8.1.1.2g.9 SR 3.8.1.16 ------------------------------NOTE------------------------------- 3 This Surveillance shall not normally be performed in 1 MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided DOC L12 an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

4.8.1.1.2g ---------------------------------------------------------------------

E 1 Verify each DG: [ [18] months 2

a. Synchronizes with offsite power source while OR loaded with emergency loads upon a simulated restoration of offsite power, In accordance with the
b. Transfers loads to offsite power source, and Surveillance Frequency
c. Returns to ready-to-load operation. Control Program ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-15 Rev. 5.0 1

CTS ITS 3.8.1 1

INSERT 9 R2 4.8.1.1.2.g.7) 2300 kW and 2500 kW (Unit 3), 2650 kW and 2850 kW (Unit 4)

Insert Page 3.8.1-15

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 16 For the unit EDGs, this 3 4.8.1.1.2g.10) SR 3.8.1.17 ------------------------------NOTE-------------------------------

2 1

[ This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish DOC L12 OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

4.8.1.1.2g ---------------------------------------------------------------------

E Verify, with a DG operating in test mode and [ [18] months 1 DOC L13 connected to its bus, an actual or simulated ESF 2 actuation signal overrides the test mode by: OR E

a. Returning DG to ready-to-load operation and In accordance 1 with the
b. [Automatically energizing the emergency load Surveillance from offsite power]. Frequency 2 Control Program ]

17 For the unit EDGs, this 4.8.1.1.2g.12) SR 3.8.1.18 ------------------------------NOTE------------------------------- 3 2 1

[ This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY DOC L12 provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be 2

taken for unplanned events that satisfy this SR. ]

4.8.1.1.2g ---------------------------------------------------------------------

Verify interval between each sequenced load block [ [18] months 2

is within +/- [10% of design interval] for each emergency [and shutdown] load sequencer. OR In accordance with the Surveillance Frequency Control Program ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-16 Rev. 5.0 1

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 18 3 4.8.1.1.2g.6) a) and b) SR 3.8.1.19 ------------------------------NOTES-----------------------------

E 1

4.8.1.1.2*

1. All DG starts may be preceded by an engine prelube period.

For the unit EDGs, this

2. This Surveillance shall not normally be 1 performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed DOC L12 to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

4.8.1.1.2g ---------------------------------------------------------------------

Verify on an actual or simulated loss of offsite power [ [18] months signal in conjunction with an actual or simulated 2 ESF actuation signal: OR

a. De-energization of emergency buses, In accordance with the
b. Load shedding from emergency buses, and Surveillance E Frequency
c. DG auto-starts from standby condition and: Control Program ] 1 2
1. Energizes permanently connected loads in

[10] seconds, 2 15

2. Energizes auto-connected emergency loads through load sequencer,
3. Achieves steady state voltage [3740] V and [4580] V, 3950 4350
4. Achieves steady state frequency 2

[58.8] Hz and [61.2] Hz, and 59.4 60.6

5. Supplies permanently connected [and auto-connected] emergency loads for 5 minutes.

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-17 Rev. 5.0 1

CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 19 3 4.8.1.1.2h SR 3.8.1.20 ------------------------------NOTE-------------------------------

E 1

4.8.1.1.2* All DG starts may be preceded by an engine prelube period.

Verify when started simultaneously from standby [ 10 years condition, each DG achieves: required E 1 15 3950 OR

a. In [10] seconds, voltage [3740] V and frequency [58.8] Hz and In accordance 59.4 3950 4350 with the 2
b. Steady state voltage [3744] V and [4576] V, Surveillance and frequency [58.8] Hz and [61.2] Hz. Frequency 59.4 60.6 Control Program ]

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.1-18 Rev. 5.0 1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Changes have been made to add or delete Actions, the subsequent Actions and Required Actions have been renumbered to reflect the additions and deletions.
4. ISTS 3.8.1, ACTION F (ITS 3.8.1 ACTION G), Reviewers Note states that this R2 Condition may be deleted if the unit design is such that any sequencer failure will only affect the ability of the associated diesel generator to power its respective safety loads. This is not the design at the Turkey Point Nuclear Generating Station (PTN);

therefore, this Condition is retained along with the associated Limiting Condition for Operation (LCO) statement and surveillance requirement.

5. ISTS Surveillance Requirement (SR) 3.8.1.15 includes Note 1 that states, in part, that momentary transients outside of load range do not invalidate this test. This statement refers to the operation also described in the Note. This operation is not a test but a prerequisite for the test, so the wording has been changed to reflect that the pre-test requirements are not invalidated by momentary transients outside the loaded range.
6. The ISTS is based on a single plant design with two redundant trains/subsystems.

Due to the shared systems between the units, the current PTN Specification is presented on facility basis instead of a unit basis. Therefore, changes are made (additions, deletions, and/or changes) to the ISTS presentation that reflect the plant-specific multi-unit and shared systems design on a unit basis. The changes do not represent a change to the plant design or safety analysis basis. These changes are consistent with the ITS presentation of other multi-unit sites with shared systems and made to align the PTN Technical Specifications, as reasonably practical, with the ISTS. Refer to Catawba Nuclear Station Units 1 and 2 Technical Specifications, LCO 3.8.1, AC Sources - Operating, (NRC ADAMS Accession No. ML052990150),

Edwin I. Hatch Nuclear Plant Unit 1 Technical Specifications, LCO 3.8.1, AC Sources - Operating, (NRC ADAMS Accession No. ML052930172), and Donald C.

Cook Nuclear Plant Unit 1 Technical Specifications, LCO 3.8.1, AC Sources -

Operating, (NRC ADAMS Accession No. ML053050305) for examples of this alternate ITS presentation which have been previously approved and determined acceptable.

7. The ISTS is based on a single plant design with two EDGs. Due to the shared systems between the units, the current PTN Specification requires more than two EDGs to be OPERABLE. The intent of ISTS 3.8.1, ACTION E, is to allow continued operation for a short period of time with no onsite standby AC sources (i.e., no required EDGs). Since the offsite electrical power system is the only source of AC R2 power for this level of degradation, the risk associated with continued operation for a short time could be less than that associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total Turkey Point Unit 3 and Unit 4 Page 1 of 2

JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES - OPERATING loss of AC power). Since any inadvertent generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation with two or more required EDGs inoperable is severely restricted. The intent is to avoid the R2 risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation. The Completion Time of two hours is consistent with the time for this level of degradation specified in NRC Regulatory Guide 1.93, "Periodic Testing of Diesel Generator Units used as Onsite Electric Power Systems at Nuclear Power Plants." The PTN shared electrical distribution system design requires specific opposite unit EDGs to be OPERABLE to support the Emergency Core Cooling System (ECCS), Control Room Emergency Ventilation System (CREVS), Control Room Emergency Air Temperature Control System (CREATCS), and required 125 V DC battery chargers. Therefore, ITS 3.8.1, ACTION F (ISTS 3.8.1, ACTION E), allows two or more required EDGs to be inoperable and the Required Action requires restoration of all but one required EDG to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ISTS 3.8.1 ACTION D (ITS 3.8.1 ACTION E) is modified to address the condition of one unit offsite circuit inoperable and one required opposite unit offsite inoperable (i.e., two required offsite circuits) concurrent with a required EDG inoperable. This revision is consistent with the CTS action allowing one required EDG inoperable concurrent with a startup transformer inoperable since a loss of the opposite unit startup transformer represents a loss of two required offsite circuits as presented in ITS. Additionally, since ITS 3.8.1 R2 ACTION F provides actions for three or more required EDGs inoperable and ITS 3.8.1 ACTION D provides actions for three inoperable offsite circuits, ISTS 3.8.1 Condition H (ITS 3.8.1 Condition J) is revised in the ITS to specify the combination of three or more inoperable AC sources requiring entry into LCO 3.0.3. ITS 3.8.1 Condition J states: One required EDG inoperable and two unit offsite circuits inoperable OR one required EDG inoperable and three offsite circuits inoperable OR two or more required EDGs inoperable and one or more required offsite circuits inoperable. The changes do not represent a change to the plant design or safety analysis basis. These changes continue to meet the intent of the ISTS requirement of continuing operation for a short period of time with no onsite standby AC sources and made to align the PTN Technical Specifications, as reasonably practical, with the ISTS. Refer to Edwin I. Hatch Nuclear Plant Unit 1 ITS 3.8.1, Conditions F and I R2 (NRC ADAMS Accession No. ML052930172), for an example of this alternate ITS presentation which has been previously approved and determined acceptable.

Turkey Point Unit 3 and Unit 4 Page 2 of 2

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

AC Sources - Operating B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operating startup BASES transformers BACKGROUND The unit Class 1E AC Electrical Power Distribution System AC sources Emergency diesel consist of the offsite power sources (preferred power sources, normal and generators (EDGs) alternate(s)), and the onsite standby power sources (Train A and Train B diesel generators (DGs)). As required by 10 CFR 50, Appendix A, 1 GDC 17 (Ref. 1), the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems. INSERT 1 The onsite Class 1E AC Distribution System is divided into redundant load groups (trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to two preferred offsite power sources and a single DG. 1 one or E 10 Offsite power is supplied to the unit switchyard(s) from the transmission network by [two] transmission lines. From the switchyard(s), two 2 electrically and physically separated circuits provide AC power, through

[step down station auxiliary transformers], to the 4.16 kV ESF buses. A 2 detailed description of the offsite power network and the circuits to the Class 1E ESF buses is found in the FSAR, Chapter [8] (Ref. 2). 1 2 U

An offsite circuit consists of all breakers, transformers, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESF bus(es).

Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the transformer supplying offsite power to the onsite Class 1E Distribution System. Within [1] minute after 2 the initiating signal is received, all automatic and permanently connected loads needed to recover the unit or maintain it in a safe condition are returned to service via the load sequencer.

INSERT 2 The onsite standby power source for each 4.16 kV ESF bus is a E

dedicated DG. DGs [11] and [12] are dedicated to ESF buses [11] 2

, and [12], respectively. A DG starts automatically on a safety injection (SI) 1 INSERT 3 signal (i.e., low pressurizer pressure or high containment pressure signals) or on an [ESF bus degraded voltage or undervoltage signal]

E (refer to LCO 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation"). After the DG has started, it will automatically tie to its 1 respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of or coincident with an E

SI signal. The DGs will also start and operate in the standby mode 1 without tying to the ESF bus on an SI signal alone. Following the trip of offsite power, [a sequencer/an undervoltage signal] strips nonpermanent 2 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-1 Rev. 5.0 1

B 3.8.1 1

INSERT 1 Offsite circuits and EDGs are shared between the Units. Units 3 and 4 were designed prior to R2 the implementation of 10 CFR 50, Appendix A, General Design Criteria (GDC) for Nuclear Power Plants, and utilized the criteria of 1967 AEC proposed GDC 39, "Emergency Power for Engineered Safety Features," in the design of the site electric power systems.

The normal power source to the Class 1E AC Electrical Power Distribution System is the respective unit auxiliary transformers and associated circuits to the Train A and B 4.16 kV buses. The preferred offsite power source is the unit startup transformer and associated circuit to the Train A and B 4.16 kV buses. One offsite circuit for each unit is supplied via the unit's start-up transformer. The alternate offsite circuit (i.e., delayed circuit) is supplied by the adjacent unit's start-up transformer to the Train A 4.16 kV bus. Manual operator action is required to align the adjacent units startup transformer to the Train A 4.16 kV bus. Each start-up transformer is connected by separate, independent highlines to separate buses in the switchyard. Each transformer is connected to the unit's Class 1E AC Electrical Power Distribution System via separate cables and breakers. No single failure can affect both circuits simultaneously or consequentially such that both circuits are lost. Each startup transformer has the capability to supply backup power of approximately 2500 kW (equivalent to the lowest EDG continuous rating) to the opposite unit's Train A 4.16 kV bus while simultaneously providing power to the units Train B 4.16 kV bus.

1 INSERT 2 Two EDGs provide onsite emergency AC power for each unit. EDGs 3A and 3B provide Unit 3 A train, and B train emergency power, respectively. EDGs 4A and 4B provide Unit 4 A train and B train emergency power, respectively.

1 INSERT 3 High Differential Pressure Between the Steam Line Header and any Steam Line, or Steam Line flowHigh Coincident with: Steam Generator PressureLow or Tavg--Low Insert Page B 3.8.1-1

AC Sources - Operating B 3.8.1 BASES BACKGROUND (continued)

E loads from the ESF bus. When the DG is tied to the ESF bus, loads are 1 then sequentially connected to its respective ESF bus by the automatic load sequencer. The sequencing logic controls the permissive and E

starting signals to motor breakers to prevent overloading the DG by 1 automatic load application.

offsite In the event of a loss of preferred power, the ESF electrical loads are 1 E

automatically connected to the DGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a loss of coolant accident (LOCA).

Certain required unit loads are returned to service in a predetermined E

sequence in order to prevent overloading the DG in the process. Within 1

[ 1] minute after the initiating signal is received, all loads needed to 2 recover the unit or maintain it in a safe condition are returned to service.

INSERT 4 Unit 4 E Ratings for Train A and Train B DGs satisfy the requirements of E 1 with exceptions Regulatory Guide 1.9 (Ref. 3). The continuous service rating of each DG INSERT 5 is [ 7000] kW with [ 10] % overload permissible for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 2 INSERT 5A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. The ESF loads that are powered from the 4.16 kV ESF buses are listed in Reference 2.

U APPLICABLE 14 The initial conditions of DBA and transient analyses in the FSAR, 1 SAFETY Chapter [ 6] (Ref. 4) and Chapter [ 15] (Ref. 5), assume ESF systems are 2 ANALYSES OPERABLE. The AC electrical power sources are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System (RCS), and containment design limits are not exceeded.

These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS);

and Section 3.6, Containment Systems.

The OPERABILITY of the AC electrical power sources is consistent with the initial assumptions of the Accident analyses and is based upon meeting the design basis of the unit. This results in maintaining at least one train of the onsite or offsite AC sources OPERABLE during Accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC power and 1
b. A worst case single failure.

The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-2 Rev. 5.0 1

B 3.8.1 1

INSERT 4 EDGs 3A and 3B, previously labeled as A and B, were the two original safety related EDGs which comprised the onsite standby power source and were used to provide all the emergency AC power for both units. As part of the Emergency Power System (EPS) Enhancement Project modifications made during the 1990-1991 Dual Unit Outage, these EDGs were relabeled as 3A and 3B and were realigned to power the Unit 3 loads and some common loads. These EDGs were procured prior to issuance of Regulatory Guide 1.9 (Ref. 3), however, all the required automatic and manual loads powered by EDGs 3A and 3B are within the continuous rating of these EDGs. Two new EDGs were aligned as the emergency AC power supplies for Unit 4.

The EDG 4A supplies power to the Unit 4A power train and the EDG 4B supplies the Unit 4B power train. The selection, design, and qualification of EDGs 4A and 4B and their associated auxiliary systems comply with the requirements of this regulatory guide with certain exceptions.

1 INSERT 5 2500 kW for the Unit 3 EDGs and 2874 kW for the Unit 4 EDGs 1

INSERT 5A The EDGs auxiliaries are powered by motor control centers (MCCs) that are supplied from their respective EDGs; MCCs 3A and 3K for EDGs 3A and 3B, respectively, and MCCs 4J and 4K for EDGs 4A and 4B, respectively.

Insert Page B 3.8.1-2

AC Sources - Operating B 3.8.1 BASES INSERT 6 LCO Two qualified circuits between the offsite transmission network and the onsite Class 1E Electrical Power System and separate and independent 1 DGs for each train ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an anticipated operational occurrence (AOO) or a postulated DBA.

Qualified offsite circuits are those that are described in the FSAR and are 1 part of the licensing basis for the unit. U

[ In addition, one required automatic load sequencer per train must be 2 OPERABLE. ]

Each offsite circuit must be capable of providing three phases of AC power, maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the ESF buses.

INSERT 7

[ Offsite circuit #1 consists of Safeguards Transformer B, which is supplied from Switchyard Bus B, and is fed through breaker 52-3 powering the ESF transformer XNB01, which, in turn, powers the #1 ESF bus through 2

its normal feeder breaker. Offsite circuit #2 consists of the Startup Transformer, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201, powering the ESF transformer, which, in turn, powers the #2 ESF bus through its normal feeder breaker. ]

E 1

Each DG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus E 15 undervoltage. This will be accomplished within [10] seconds. Each DG 2 1 must also be capable of accepting required loads within the assumed loading sequence intervals and continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met E

from a variety of initial conditions such as DG in standby with the engine hot and DG in standby with the engine at ambient conditions. Additional 1

DG capabilities must be demonstrated to meet required Surveillance, E

e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode. a safety injection actuation Proper sequencing of loads, [including tripping of nonessential loads,] is a 2 E

required function for DG OPERABILITY. 1 The AC sources in one train must be separate and independent (to the E

extent possible) of the AC sources in the other train. For the DGs, 1 separation and independence are complete.

For the offsite AC sources, separation and independence are to the extent practical. A circuit may be connected to more than one ESF bus, INSERT 8 with fast transfer capability to the other circuit OPERABLE, and not violate separation criteria. A circuit that is not connected to an ESF bus is 1 required to have OPERABLE fast transfer interlock mechanisms to at least two ESF buses to support OPERABILITY of that circuit.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-3 Rev. 5.0 1

B 3.8.1 1

INSERT 6 Two qualified circuits between the offsite transmission network and the unit onsite Class 1E AC Electrical Power Distribution System, two unit emergency diesel generators capable of supplying the onsite Class 1E AC Electrical Power Distribution System, one qualified circuit between the offsite transmission network and the opposite unit onsite Class 1E AC electrical Power distribution train(s) needed to support equipment required by LCO 3.5.2, ECCS -

Operating, LCO 3.7.10, Control Room Emergency Ventilation System (CREVS), LCO 3.7.11, Control Room Emergency Air Temperature Control System (CREATCS)," and LCO 3.8.4, DC Sources - Operating, required opposite unit EDG(s) capable of supplying power to support equipment required by LCO 3.5.2, LCO 3.7.10, LCO 3.7.11, and LCO 3.8.4, and the automatic load sequencers for Train A and Train B 1

INSERT 7 For Unit 3, the preferred offsite circuit consists of the required incoming breaker(s) and disconnects from the 240 kV switchyard to Startup Transformer No. 3 up to and including the feeder breakers to both 4.16 kV Buses 3A and 3B. The alternate offsite circuit consists of the required incoming breaker(s) and disconnects from the 240 kV switchyard to Startup Transformer No. 4 up to and including the feeder breakers to 4.16 kV Bus 3A. The opposite unit offsite circuit consists of the same incoming breaker(s) and disconnects from the 240 kV switchyard to Startup Transformer No. 4 and the circuit path up to and including the unit tie breaker to the required opposite units 4.16 kV buses (Buses 4A and 4B) needed to support ECCS, CREVS, CREATCS, and required 125 V battery chargers.

For Unit 4, the preferred offsite circuit consists of the required incoming breaker(s) and disconnects from the 240 kV switchyard to Startup Transformer No. 4 up to and including the feeder breakers to both 4.16 kV Buses 4A and 4B. The alternate offsite circuit consists of the required incoming breaker(s) and disconnects from the 240 kV switchyard to Startup Transformer No. 3 up to and including the unit tie breaker to 4.16 kV Bus 4A. The opposite unit offsite circuit consists of the same incoming breaker(s) and disconnects from the 240 kV switchyard to Startup Transformer No. 3 and the circuit path up to and including the feeder breakers to the required opposite units 4.16 kV buses (Buses 3A and 3B) needed to support ECCS, CREVS, CREATCS, and required 125 V battery chargers.

To preclude inadvertent connecting of both startup transformers, the unit tie breaker to the respective Train A 4.16 kV bus does not include automatic transfer capability and is normally racked out and locked open. Upon a loss of the main generator and the preferred offsite circuit, the alternate offsite circuit is connected to the Train A bus by unlocking, racking in, and closing the unit tie breaker to restore offsite power to the unit Train A 4.16 kV bus.

Insert Page B 3.8.1-3a

B 3.8.1 1

INSERT 8 When the preferred offsite circuit is not connected to the 4.16 kV buses, automatic fast transfer capability from the unit auxiliary transformer to the startup transformer must be OPERABLE to both Train A and B buses. When the alternate offsite circuit (i.e., delayed circuit from opposite unit startup transformer) is not connected to the Train A 4.16 kV bus, manual transfer capability to the Train A bus must be available with an OPERABLE unit tie breaker available to rack in and close. When the opposite unit offsite circuit is not connected to the required opposite unit 4.16 kV buses, automatic fast transfer capability from the opposite unit's auxiliary transformer to the opposite unit's startup transformer must be OPERABLE to the required opposite unit 4.16 kV buses.

Insert Page B 3.8.1-3b

AC Sources - Operating B 3.8.1 BASES APPLICABILITY The AC sources [and sequencers] are required to be OPERABLE in 2 MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and
b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 5 and 6 are covered in LCO 3.8.2, "AC Sources - Shutdown."

E ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable DG. 1 E

There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the 1 provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 unit To ensure a highly reliable power source remains with one offsite circuit 1 inoperable, it is necessary to verify the OPERABILITY of the remaining s 1 required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, D

and Condition C, for two offsite circuits inoperable, is entered. 3

REVIEWERS NOTE-----------------------------------

The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater 4

pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-4 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

A.2 Required Action A.2, which only applies if the train cannot be powered E

from an offsite source, is intended to provide assurance that an event coincident with a single failure of the associated DG will not result in a 1 complete loss of safety function of critical redundant required features.

These features are powered from the redundant AC electrical power train.

This includes motor driven auxiliary feedwater pumps. Single train 1 systems, such as turbine driven auxiliary feedwater pumps, may not be included.

The Completion Time for Required Action A.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. The train has no offsite power supplying it loads and
b. A required feature on the other train is inoperable.

unit If at any time during the existence of Condition A (one offsite circuit 1 inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power to one train of the onsite Class 1E Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

E The remaining OPERABLE offsite circuit and DGs are adequate to supply 1 electrical power to Train A and Train B of the onsite Class 1E Distribution System. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-5 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

A.3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. [Alternatively, a 2 Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] With one offsite circuit inoperable, 2 the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining E

OPERABLE offsite circuit and DGs are adequate to supply electrical 1 power to the onsite Class 1E Distribution System.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

INSERT 9 C

B.1 3 E

To ensure a highly reliable power source remains with an inoperable DG, 1 it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

REVIEWERS NOTE-----------------------------------

The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that the remaining OPERABLE motor or turbine driven auxiliary feedwater 4 pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

C 3 B.2 C

Required Action B.2 is intended to provide assurance that a loss of offsite 3 E

power, during the period that a DG is inoperable, does not result in a 1 complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven 1

auxiliary feedwater pumps. Single train systems, such as turbine driven Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-6 Rev. 5.0 1

B 3.8.1 1

3 INSERT 9 B.1 To ensure a highly reliable power source remains with one opposite unit offsite circuit inoperable, it is necessary to verify the OPERABILITY of the remaining unit offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition D, for two offsite circuits inoperable, is entered.

B.2 Required Action B.2, which only applies if the train cannot be powered from a qualified offsite source, is intended to provide assurance that an event coincident with a single failure of the associated EDG will not result in a complete loss of safety function of critical redundant required features. These features are powered from the redundant AC electrical power train. Single train systems may not be included.

The Completion Time for Required Action B.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. The train has no offsite power supplying it loads and
b. A required feature on another required train (associated unit or opposite unit) is inoperable.

If at any time during the existence of Condition B (one opposite unit offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power to one train of the onsite Class 1E Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE unit offsite circuit(s) and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution System. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

Insert Page B 3.8.1-6a

B 3.8.1 3

INSERT 9 (cont)

B.3 With the opposite unit offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE EDGs are adequate to supply electrical power to the onsite Class 1E Distribution System.

The 30 day Completion Time takes into account the limited number of opposite unit trains, subsystems, and components required (e.g., one SI subsystem, one CREVS train, one CREATCS train, and required battery chargers), capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

Insert Page B 3.8.1-6b

AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) auxiliary feedwater pumps, are not included. Redundant required feature 1 failures consist of inoperable features associated with a train, redundant E

to the train that has an inoperable DG. 1 C

The Completion Time for Required Action B.2 is intended to allow the 3 operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

E 1

a. An inoperable DG exists and another required
b. A required feature on the other train (Train A or Train B) is 1 inoperable.

E 1

If at any time during the existence of this Condition (one DG inoperable) a required feature subsequently becomes inoperable, this Completion Time would begin to be tracked.

E 1

Discovering one required DG inoperable coincident with one or more inoperable required support or supported features, or both, that are EDGs associated with the OPERABLE DG, results in starting the Completion 1 Time for the Required Action. Four hours from the discovery of these events existing concurrently is Acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

E 1

In this Condition, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

C B.3.1 and B.3.2 3

Required Action B.3.1 provides an allowance to avoid unnecessary

, such as an inoperable support E

testing of OPERABLE DG(s). If it can be determined that the cause of system, an independently 6 the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 testable component, or 1 preplanned preventative E does not have to be performed. If the cause of inoperability exists on maintenance or testing, other DG(s), the other DG(s) would be declared inoperable upon F

discovery and Condition E of LCO 3.8.1 would be entered. Once the failure is repaired, the common cause failure no longer exists, and Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-7 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

C E

Required Action B.3.1 is satisfied. If the cause of the initial inoperable 2 DG cannot be confirmed not to exist on the remaining DG(s), 1 6

performance of SR 3.8.1.2 suffices to provide assurance of continued 5 E

OPERABILITY of that DG. 1 E

In the event the inoperable DG is restored to OPERABLE status prior to 1 C

completing either B.3.1 or B.3.2, the [plant corrective action program] will 3 2 continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> constraint imposed C 3 while in Condition B.

According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to 2 E

confirm that the OPERABLE DG(s) is not affected by the same problem 1

as the inoperable DG.

C 3 B.4 INSERT 10 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

In Condition B, the remaining OPERABLE DG and offsite circuits are 1

adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

[Alternatively, a Completion Time can be determined in accordance with 2 the Risk Informed Completion Time Program.]

D C.1 and C.2 3 unit or three offsite circuits 6

Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps.

Single train features, such as turbine driven auxiliary pumps, are not 1 included in the list.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-8 Rev. 5.0 1

B 3.8.1 1

INSERT 10 In Condition C, the remaining OPERABLE EDGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. An evaluation was performed to evaluate the risk associated with extending the Completion Time for a single inoperable EDG from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days from both a qualitative and quantitative perspective and found it to be acceptable (Ref. 12).

In MODES 1, 2, and 3, if an EDG is to be removed from service for maintenance for a period scheduled to exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the following restrictions apply:

  • If an EDG is unavailable, an EDG on the opposite unit will be removed from service only for corrective maintenance, i.e., maintenance required to ensure or restore OPERABILITY.
  • If the blackout crosstie is unavailable, an EDG will be removed from service only for corrective maintenance, i.e., maintenance required to ensure or restore OPERABILITY.
  • If an EDG is unavailable, the blackout crosstie will be removed from service only for corrective maintenance, i.e., maintenance required to ensure or restore OPERABILITY.
  • If a condition is entered in which both an EDG and the blackout crosstie are unavailable at the same time, restore the EDG or blackout crosstie to service as soon as possible.
  • If an EDG is unavailable, the startup transformer will be removed from service only for corrective maintenance, i.e., maintenance required to ensure or restore OPERABILITY.
  • If the startup transformer is unavailable, an EDG will be removed from service only for corrective maintenance, i.e., maintenance required to ensure or restore OPERABILITY.

In addition, positive measures in the form of administrative controls and guidelines do not allow maintenance to be planned on EDGs when adverse weather conditions (hurricanes and tornadoes) are expected, such as

  • If a hurricane warning has been issued in an area which may impact the Florida Power &

Light Company (FPL) grid, i.e., within the FPL service area, an EDG or the Blackout Crosstie should be removed from service only for corrective maintenance, i.e.,

maintenance required to ensure or restore OPERABILITY.

  • If an EDG or the Blackout Crosstie is unavailable when a hurricane warning in an area that may impact the FPL grid is issued, the unavailable components will be restored to service as soon as possible.
  • If a tornado watch has been issued for an area which includes the Turkey Point Plant site, and/or the substations and transmission lines serving Turkey Point Plant switchyard, restore the unavailable components to service as soon as possible.

Insert Page B 3.8.1-8a

B 3.8.1 1

INSERT 10 (cont.)

To address the potential fire risk implications during MODES 1, 2, and 3, if an EDG is to be removed from service for maintenance for a period scheduled to exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the following actions will be completed:

  • A plant fire protection walkdown of the areas that could impact EDG availability, offsite power availability or the ability to use the Station Blackout Crosstie prior to entering the extended allowed outage time (AOT).
  • A thermographic examination of high-risk potential ignition sources in the Cable Spreading Room and the Control Room,
  • Restriction of planned hot work in the Cable Spreading Room and Control Room during the extended AOT, and

In addition to the predetermined restrictions, assessments performed in accordance with the provisions of the Maintenance Rule (a)(4) will ensure that any other risk significant configurations are identified before removing an EDG from service for pre-planned maintenance.

Insert Page B 3.8.1-8b

AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

D The Completion Time for Required Action C.1 is intended to allow the 3 operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. All required offsite circuits are inoperable and
b. A required feature is inoperable.

D If at any time during the existence of Condition C (two offsite circuits 3 inoperable) a required feature becomes inoperable, this Completion Time begins to be tracked.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in D

Condition C for a period that should not exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. [Alternatively, 3 2 a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.] This level of degradation means 2 that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

Because of the normally high availability of the offsite sources, this level E

of degradation may appear to be more severe than other combinations of 1

two AC sources inoperable that involve one or more DGs inoperable.

However, two factors tend to decrease the severity of this level of degradation:

a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure and
b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

With both of the required offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-9 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

According to Reference 6, with the available offsite AC sources, two less than required by the LCO, operation may continue for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If two offsite sources are restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unrestricted operation may continue. If only one offsite source is restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, power operation continues in accordance with Condition A.

E D.1 and D.2 3 Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Required Actions of Condition D are 3 E

modified by a Note to indicate that when Condition D is entered with no AC source to any train, the Conditions and Required Actions for This Condition applies to the LCO 3.8.9, "Distribution Systems - Operating," must be immediately combination of one required E 3 offsite circuit inoperable entered. This allows Condition D to provide requirements for the loss of E

concurrent with one required one offsite circuit and one DG, without regard to whether a train is de- 1 EDG inoperable. This energized. LCO 3.8.9 provides the appropriate restrictions for a de-Condition also applies when a unit offsite circuit is energized train.

inoperable concurrent with a required opposite unit offsite According to Regulatory Guide 1.93 (Ref. 6), operation may continue in circuit inoperable (e.g., the R2 opposite unit startup Condition D for a period that should not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. [Alternatively, 1 transformer is inoperable) and a Completion Time can be determined in accordance with the Risk one required EDG inoperable.

If two unit offsite circuits (i.e.,

Informed Completion Time Program.]

both the preferred and E 3 alternate offsite circuits) are In Condition D, individual redundancy is lost in both the offsite electrical inoperable concurrent with a required EDG inoperable, power system and the onsite AC electrical power system. Since power Condition J must also be system redundancy is provided by two diverse sources of power, entered. however, the reliability of the power systems in this Condition may appear D 3 R2 unit offsite circuits or all three higher than that in Condition C (loss of both required offsite circuits). This difference in reliability is offset by the susceptibility of this power system 72 configuration to a single bus or switching failure. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion 1 Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. [Alternatively, a Completion Time can be 2 determined in accordance with the Risk Informed Completion Time Program.] 2 F

E.1 3 two or more required E With Train A and Train B DGs inoperable, there are no remaining standby 1 R2 AC sources. Thus, with an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions. Since the offsite electrical power system is the only source of AC power for this level of degradation, the risk associated with continued operation for a very short time could be less than that Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-10 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC power). Since any inadvertent generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

all required E R2 According to Reference 6, with both DGs inoperable, operation may 1 continue for a period that should not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

R2 G R2 3

[ F.1 E

The sequencer(s) is an essential support system to [both the offsite circuit 2 and the DG associated with a given ESF bus]. [Furthermore, the 1 sequencer is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus.]

2 Therefore, loss of an [ESF bus sequencer] affects every major ESF train system in the [division]. The [12] hour Completion Time provides a period 72 of time to correct the problem commensurate with the importance of maintaining sequencer OPERABILITY. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion 2 Time Program.] This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

This Condition is preceded by a Note that allows the Condition to be deleted if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads under any conditions. Implicit in this Note is the concept that the Condition must be retained if any sequencer failure mode results in the 4 inability to start all or part of the safety loads when required, regardless of power availability, or results in overloading the offsite power circuit to a safety bus during an event and thereby causes its failure. Also implicit in the Note, is that the Condition is not applicable to any train that does not have a sequencer. ]

H R2 3

G.1 and G.2 If the inoperable AC electric power sources cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

INSERT 11 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-11 Rev. 5.0 1

B 3.8.1 R2 1

INSERT 11 Condition H is modified by a Note stating that the Condition is not applicable when a dual unit R2 shutdown is required. When a single unit is affected, the time to be in MODE 3 is 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

When a Required Action requires a dual unit shutdown, the time to be in MODE 3 is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

This is to allow the orderly shutdown of one unit at a time and not jeopardize the stability of the electrical grid by imposing a dual unit shutdown.

Insert Page B 3.8.1-11 R2

AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven auxiliary feedwater pump 1 must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

H R2 Required Action G.2 is modified by a Note that states that LCO 3.0.4.a is 3 not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

INSERT 12 J R2 H.1 3 may have Condition H corresponds to a level of degradation in which all redundancy 3 in the AC electrical power supplies has been lost. At this severely 1 R2 due to the combination of inoperable AC sources degraded level, any further losses in the AC electrical power system will R2 cause a loss of function. Therefore, no additional time is justified for R2 may continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and testing of all 39 REQUIREMENTS important areas and features, especially those that have a standby 1 1967 draft AEC function, in accordance with 10 CFR 50, Appendix A, GDC 18 (Ref. 9). 1 Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs E

for demonstrating the OPERABILITY of the DGs are in accordance with 1 the recommendations of Regulatory Guide 1.9 (Ref. 3), Regulatory 9 10 Guide 1.108 (Ref. 10), and Regulatory Guide 1.137 (Ref. 11), as 1 addressed in the FSAR.

U Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-12 Rev. 5.0 1

B 3.8.1 1

INSERT 12 I.1 and I.2 R2 If the inoperable AC electric power sources cannot be restored to OPERABLE status within the required Completion Time and a dual unit shutdown is required, the units must be brought to a MODE in which overall plant risk is reduced. To achieve this status safely, the units are shut down consecutively such that both units are brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

Condition I is modified a Note. The Note states that the Condition only applies when a dual unit R2 shutdown is required. To achieve a consecutive unit shutdown, the first unit should be in MODE 3 and MODE 4 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, respectively, to allow time for the second unit to reach MODE 3 and MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, respectively. This is to allow for the orderly shutdown of one unit at a time and not jeopardize the stability of the electrical grid by imposing a simultaneous dual unit shutdown.

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action I.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when R2 entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

Insert Page B 3.8.1-12

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. The minimum steady state output 3950 V is 95%

voltage of [3740] V is 90% of the nominal 4160 V output voltage. This 2 value, which is specified in ANSI C84.1 (Ref. 12), allows for voltage drop 1 to the terminals of 4000 V motors whose minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plate rating.

The specified maximum steady state output voltage of [4756] V is equal to the maximum operating voltage specified for 4000 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating 1 voltages. The specified minimum and maximum frequencies of the DG are 58.8 Hz and 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz nominal frequency and are derived from the recommendations given in Regulatory Guide 1.9 (Ref. 3). INSERT 13 SR 3.8.1.1 This SR ensures correct breaker alignment for each [required] offsite 2 circuit to ensure that distribution buses and loads are connected to their offsite preferred power source, and that appropriate independence of offsite 1 circuits is maintained. The SR also verifies the indicated availability of three-phase AC electrical power from each [required] offsite circuit to the onsite distribution network. [ The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware 2

of it and because its status is displayed in the control room.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the 4 Surveillance Requirement.

]

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-13 Rev. 5.0 1

B 3.8.1 1

INSERT 13 The steady state voltage and frequency limits of 3950V to 4350V and 60 +/- 0.6 Hz are derived from the worst case EDG loading conditions established during the Extended Power Uprate (EPU) evaluation. The minimum voltage limit (3950V) of the EDG at the 4.16 kV buses, with line losses accounted for, will be above the minimum required running voltage of 3600V (90%)

of all 4000V motors. The maximum voltage limit (4350V) of the EDG at the 4.16 kV buses is below the maximum required running voltage limit of 4400V (110%) of all 4000V motors.

Insert Page B 3.8.1-13

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.2 and SR 3.8.1.7 These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and to maintain the unit in a safe shutdown condition.

To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs are modified by a Note (Note 1 for SR 3.8.1.2 and Note for SR 3.8.1.7) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup period prior to loading.

For the purposes of SR 3.8.1.2 and SR 3.8.1.7 testing, the DGs are started from standby conditions. Standby conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations.

[ In order to reduce stress and wear on diesel engines, some manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are 5 gradually accelerated to synchronous speed prior to loading. These start procedures are the intent of Note 2, which is only applicable when such modified start procedures are recommended by the manufacturer. ]

SR 3.8.1.7 requires that the DG starts from standby conditions and achieves required voltage and frequency within 10 seconds. The 10 second start requirement supports the assumptions of the design basis LOCA analysis in the FSAR, Chapter [15] (Ref. 5).

The 10 second start requirement is not applicable to SR 3.8.1.2 (see Note 2) when a modified start procedure as described above is used. If a modified start is not used, the 10 second start requirement of SR 3.8.1.7 applies.

Since SR 3.8.1.7 requires a 10 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2.

In addition to the SR requirements, the time for the DG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-14 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref. 3). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing.

OR The Surveillance Frequency is controlled under the Surveillance 5 Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

2 SR 3.8.1.3 5 E

This Surveillance verifies that the DGs are capable of synchronizing with 1 the offsite electrical system and accepting loads greater than or equal to the equivalent of the maximum expected accident loads. A minimum run E

time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source. 1 E Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between [ 0.8 lagging] and 1

[ 1.0] . The [ 0.8] value is the design rating of the machine, while the [ 1.0] is 2 E

an operational limitation [ to ensure circulating currents are minimized] .

The load band is provided to avoid routine overloading of the DG. 1 Routine overloading may result in more frequent teardown inspections in E

accordance with vendor recommendations in order to maintain DG 1 OPERABILITY.

[ The 31 day Frequency for this Surveillance is consistent with Regulatory Guide 1.9 (Ref. 3). 2 For Unit 3 EDGs this test continues until automatic transfer of fuel from the day tank to the skid OR mounted tank is demonstrated, and the cooling system operation is demonstrated.

1 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-15 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR is modified by four Notes. Note 1 indicates that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 states that momentary transients, because of changing bus loads, do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test. Note 3 E

indicates that this Surveillance should be conducted on only one DG at a 1 time in order to avoid common cause failures that might result from offsite E

circuit or grid perturbations. Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test 1 to credit satisfactory performance.

3 SR 3.8.1.4 5 Unit 3 skid tank This SR provides verification that the level of fuel oil in the day tank [ and 2 engine mounted tank] is at or above the level at which fuel oil is automatically added. The level is expressed as an equivalent volume in INSERT 14 gallons, and is selected to ensure adequate fuel oil for a minimum of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of DG operation at full load plus 10%. 1

[ The 31 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility operators would be aware of any large uses of fuel oil during this period. 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-16 Rev. 5.0 1

B 3.8.1 1

INSERT 14 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> for Unit 3 EDGs based on a historical LOOP scenario and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for Unit 4 EDGs.

Insert Page B 3.8.1-16

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 4 SR 3.8.1.5 5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the Unit 3 skid tank fuel oil day [ and engine mounted] tanks eliminates the necessary 2 environment for bacterial survival. This is the most effective means of E

controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may 1 come from any of several sources, including condensation, groundwater, rainwater, contaminated fuel oil, and breakdown of the fuel oil by bacteria.

Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. [ The Surveillance Frequency of 31 days is established by Regulatory Guide 1.137 (Ref. 11). This SR is for preventative maintenance. 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during the performance of this Surveillance.

5 SR 3.8.1.6 5 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-17 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

INSERT 15

[ The Frequency for this SR is variable, depending on individual system design, with up to a [ 92] day interval. The [ 92] day Frequency corresponds to the testing requirements for pumps as contained in the ASME Code (Ref. 12); however, the design of fuel transfer systems is such that pumps operate automatically or must be started manually in order to maintain an adequate volume of fuel oil in the day [ and engine 2 mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABILITY, the Frequency of this SR should be modified to reflect individual designs.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

6 SR 3.8.1.7 5 See SR 3.8.1.2. INSERT 16 7

[ SR 3.8.1.8 5 Transfer of each [ 4.16 kV ESF bus] power supply from the normal offsite 2 auxiliary transformer circuit to the alternate offsite circuit demonstrates the OPERABILITY of 1 startup transformer the alternate circuit distribution network to power the shutdown loads.

[ The [ 18 month] Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [ 18 month] Frequency. Therefore, 2 the Frequency was concluded to be acceptable from a reliability standpoint.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-18 Rev. 5.0 1

B 3.8.1 1

INSERT 15 This SR is modified by a Note. This Note allows for the use of a temporary system for storage and delivery of at least a 7 day supply of diesel fuel for one Unit 3 EDG. The capability of this temporary system to deliver fuel will maintain the OPERABILITY of the EDG for ten days. If ten days of operation are exceeded using the temporary fuel storage system, action statements for an inoperable but required Unit 3 EDG will require the shutdown of Unit 4 and suspension of the Unit 3 refueling process. This temporary fuel oil storage system provides for OPERABILITY of any EDG normally fed from the Unit 3 fuel oil storage system while the normal diesel fuel storage tank is having its accumulated sediment removed and is being cleaned and or repaired.

Prior to taking the Unit 3 fuel oil storage tank (FOST) out of service the levels of U3 Day Tanks and Skid Tanks as well as the U4 FOSTs shall be controlled in accordance with the applicable U3 EDG Temporary Diesel Fuel Oil Supply Procedure.

The Unit 3 EDG 2000 gallon minimum day/skid tank fuel supply will enable the highest loaded EDG (i.e., 3B EDG) to operate for a minimum of 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />. Either of the Unit 3 fuel oil transfer pumps can be manually aligned to provide diesel oil flow to either or both of the diesel day tanks associated with EDGs 3A and 3B.

5 INSERT 16 This SR helps to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and to maintain the unit in a safe shutdown condition.

To minimize the wear on moving parts that do not get lubricated when the engine is not running, this SR is modified by a Note to indicate that all EDG starts for this Surveillance may be preceded by an engine prelube period.

The EDGs are started from standby conditions. Standby conditions for a EDG mean that the diesel engine oil is being continuously circulated via the standby pumps and temperature is being maintained consistent with manufacturer recommendations.

SR 3.8.1.6 requires that the EDG starts from standby conditions and achieves required voltage and frequency within 15 seconds. The 15 second start requirement supports the assumptions of the design basis LOCA analysis in the UFSAR, Chapter 14 (Ref. 5).

In addition to the SR requirements, the time for the EDG to reach steady state operation is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.

The EDG should be started for this test by using one of the following signals: a) manual, or b) simulated loss-of-offsite power by itself, or c) simulated loss-of-offsite power in conjunction with an ESF actuation test signal, or d) an ESF actuation test signal by itself.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Insert Page B 3.8.1-18

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR is modified by a Note. The reason for the Note is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or 1 enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.]

Credit may be taken for unplanned events that satisfy this SR.

8 SR 3.8.1.9 5 E

Each DG is provided with an engine overspeed trip to prevent damage to 1 the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might E

result in a trip of the engine. This Surveillance demonstrates the DG load 1 response characteristics and capability to reject the largest single load without exceeding predetermined voltage and frequency and while maintaining a specified margin to the overspeed trip. [For this unit, the E 2 single load for each DG and its horsepower rating is as follows:] This 1 Surveillance may be accomplished by: INSERT 17 E

a. Tripping the DG output breaker with the DG carrying greater than or 1 equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus, or E
b. Tripping its associated single largest post-accident load with the DG 1 solely supplying the bus.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-19 Rev. 5.0 1

B 3.8.1 1

INSERT 17 the component cooling water pump having an equivalent kW rating of 380 kW. To compensate for a worst-case EDG over-frequency of 1 % the minimum rejection load specified is increased to 392 kW.

Insert Page B 3.8.1-19

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Based on Regulatory Guide 1.9 (Ref. 3),

As required by IEEE-308 (Ref. 13), the load rejection test is acceptable if 1 the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15%

above synchronous speed, whichever is lower.

The time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref. 3) recommendations for 2

response during load sequence intervals. The 3 seconds specified is 1 less than equal to 60% of a typical 5 second load sequence interval associated with sequencing of the largest load. The voltage and frequency specified are E

consistent with the design range of the equipment powered by the DG. 1 8

SR 3.8.1.9.a corresponds to the maximum frequency excursion, while 5

SR 3.8.1.9.b and SR 3.8.1.9.c are steady state voltage and frequency values to which the system must recover following load rejection. [ The

[ 18 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 10). 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge on the unit's continued steady state operation and, as a result, unit safety systems.

EDGs This restriction from normally performing the Surveillance in MODE 1 or 2 1 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-20 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

INSERT 18 E

Note 2 ensures that the DG is tested under load conditions that are as 1 close to design basis conditions as possible. When synchronized with 0.86 2 offsite power, testing should be performed at a power factor of [0.9]. E This power factor is representative of the actual inductive loading a DG 1 would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage 2 is high, and the additional field excitation needed to get the power factor to [0.9] results in voltages on the emergency busses that are too high. 2 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on 2 the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of [0.9] 1 2 may not cause unacceptable voltages on the emergency busses, but the E excitation levels are in excess of those recommended for the DG. In such 1 E

cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits. 2 1 E

REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 4
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-21 Rev. 5.0 1

B 3.8.1 1

INSERT 18 In addition, because each unit requires three EDGs to be OPERABLE (two from the associated unit and one from the opposite unit) clarification is added stating that the MODE restriction on the performance of this test applies only to the associated units' EDGs.

Insert Page B 3.8.1-21

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 9 SR 3.8.1.10 5 E

This Surveillance demonstrates the DG capability to reject a full load 1 E

without overspeed tripping or exceeding the predetermined voltage limits.

The DG full load rejection may occur because of a system fault or 1 inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test E

simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon 1

loss of the load. These acceptance criteria provide for DG damage E

protection. While the DG is not expected to experience this transient E

during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to 1 the bus if the trip initiator can be corrected or isolated.

[ The [ 18 month] Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 10) and is intended to be consistent with expected fuel cycle lengths. 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR has been modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbation to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-22 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk INSERT 19 insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR. Note 2 E

ensures that the DG is tested under load conditions that are as close to 1 design basis conditions as possible. When synchronized with offsite 0.86 power, testing should be performed at a power factor of [0.9]. This 2 E

power factor is representative of the actual inductive loading a DG would 1 see under design basis accident conditions. Under certain conditions, however, Note 2 allows the Surveillance to be conducted at a power 0.86 factor other than [0.9]. These conditions occur when grid voltage is 2 high, and the additional field excitation needed to get the power factor to 0.86

[0.9] results in voltages on the emergency busses that are too high. 2 0.86 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on 2 the emergency busses. In other circumstances, the grid voltage may be 0.86 such that the DG excitation levels needed to obtain a power factor of [0.9] 1 2 E

may not cause unacceptable voltages on the emergency busses, but the E

excitation levels are in excess of those recommended for the DG. In such 1 0.86 cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits. 2 1 E

REVIEWERS NOTE----------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 4
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-23 Rev. 5.0 1

B 3.8.1 1

INSERT 19 In addition, because each unit requires three EDGs to be OPERABLE (two from the associated unit and one from the opposite unit) clarification is added stating that the MODE restriction on the performance of this test applies only to the associated units' EDGs.

Insert Page B 3.8.1-23

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 10 SR 3.8.1.11 5 9

As required by Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(1), this 1 Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and E

respective loads from the DG. It further demonstrates the capability of 1 the DG to automatically achieve the required voltage and frequency within the specified time.

E 15 The DG autostart time of [10] seconds is derived from requirements of the 1 2 accident analysis to respond to a design basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability is achieved.

The requirement to verify the connection and power supply of permanent and autoconnected loads is intended to satisfactorily show the E

relationship of these loads to the DG loading logic. In certain 1 circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or residual heat removal (RHR) systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration E

of connection and loading of loads, testing that adequately shows the capability of the DG systems to perform these functions is acceptable. 1 This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

[ The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(1), takes into consideration unit conditions required to perform the Surveillance, and is 2

intended to be consistent with expected fuel cycle lengths.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-24 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, 1 E

the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the 1, 2, 3, or 4 Surveillance in MODE 1 or 2 is further amplified to allow portions of the 1 Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment.

Credit may be taken for unplanned events that satisfy this SR.

INSERT 20 11

[ SR 3.8.1.12 5 E

This Surveillance demonstrates that the DG automatically starts and 1 achieves the required voltage and frequency within the specified time 15

([ 10] seconds) from the design basis actuation signal (LOCA signal) and 2 a 5 minutes. The 5 minute period provides sufficient time to 11 demonstrate stability. SR 3.8.1.12.d and SR 3.8.1.12.e ensure that 5 permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-25 Rev. 5.0 1

B 3.8.1 1

INSERT 20 In addition, because each unit requires three EDGs to be OPERABLE (two from the associated unit and one from the opposite unit) clarification is added stating that the MODE restriction on the performance of this test applies only to the associated units' EDGs.

Insert Page B 3.8.1-25

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The requirement to verify the connection of permanent and E

autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of 1 these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked open, or high pressure injection systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the E

capability of the DG system to perform these functions is acceptable. 1 This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

[ The Frequency of [ 18 months] takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the [ 18 month] 2 Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, E 1 the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-26 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. ] 2 Credit may be taken for unplanned events that satisfy this SR.

INSERT 21 12 SR 3.8.1.13 5 E

This Surveillance demonstrates that DG noncritical protective functions 1 (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ESF actuation test signal. Noncritical automatic trips are all automatic trips except:

and

a. Engine overspeed; 1
b. Generator differential current; 1

[ c. Low lube oil pressure;

d. High crankcase pressure; and 2
e. Start failure relay.]

The noncritical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with E 1 sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems E 1 that are not immediately detrimental to emergency operation of the DG.

[ The [18 month] Frequency is based on engineering judgment, taking into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when 2 performed at the [18 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

OR Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-27 Rev. 5.0 1

B 3.8.1 1

INSERT 21 In addition, because each unit requires three EDGs to be OPERABLE (two from the associated unit and one from the opposite unit) clarification is added stating that the MODE restriction on the performance of this test applies only to the associated units' EDGs.

Insert Page B 3.8.1-27

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

E The SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DG from service. This 1 restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

INSERT 22

REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable, 4
b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-28 Rev. 5.0 1

B 3.8.1 1

INSERT 22 In addition, because each unit requires three EDGs to be OPERABLE (two from the associated unit and one from the opposite unit) clarification is added stating that the MODE restriction on the performance of this test applies only to the associated units' EDGs.

Insert Page B 3.8.1-28

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 13 SR 3.8.1.14 5 Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(3), requires E

demonstration that the DGs can start and run continuously at full load 1 capability for an interval of not less than 24 [ 2] hours of which is 2 at a load equivalent to 110% of the continuous duty rating and the E

remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from 1

standby or hot conditions. The provisions for prelubricating and warmup, 6

discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, 5 are applicable to this SR. 2 E

The load band is provided to avoid routine overloading of the DG. 1 E

Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG 1 OPERABILITY.

[ The [ 18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(3), takes into consideration unit conditions required to perform the Surveillance, and is 2 intended to be consistent with expected fuel cycle lengths.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

two This Surveillance is modified by three Notes. Note 1 states that 1 momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety 1

systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-29 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 1 Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment. 2 Credit may be taken for unplanned events that satisfy this SR. Note 3 E

ensures that the DG is tested under load conditions that are as close to 1 design basis conditions as possible. When synchronized with offsite 0.86 power, testing should be performed at a power factor of [0.9]. This 2 E

power factor is representative of the actual inductive loading a DG would 1 see under design basis accident conditions. Under certain conditions, at however, Note 3 allows the Surveillance to be conducted as a power 1 0.86 factor other than [0.9]. These conditions occur when grid voltage is 2 0.86 high, and the additional field excitation needed to get the power factor to

[0.9] results in voltages on the emergency busses that are too high. 2 Under these conditions, the power factor should be maintained as close 0.86 as practicable to [0.9] while still maintaining acceptable voltage limits on 2 the emergency busses. In other circumstances, the grid voltage may be 0.86 such that the DG excitation levels needed to obtain a power factor of [0.9] 1 2 E

may not cause unacceptable voltages on the emergency busses, but the E

excitation levels are in excess of those recommended for the DG. In such 1 0.86 cases, the power factor shall be maintained close as practicable to [0.9] 2 E

without exceeding the DG excitation limits. 1 14 SR 3.8.1.15 5 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 15

[10] seconds. The [10] second time is derived from the requirements of 2 the accident analysis to respond to a design basis large break LOCA.

[ The [18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(5).

2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-30 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to E

avoid routine overloading of the DG. Routine overloads may result in 1 more frequent teardown inspections in accordance with vendor E

recommendations in order to maintain DG OPERABILITY. The 1 requirement that the diesel has operated for at least [ 2] hours at full load 2 conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary E

transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to 1 minimize wear and tear on the diesel during testing.

15 SR 3.8.1.16 5 As required by Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(6), this E

Surveillance ensures that the manual synchronization and automatic load transfer from the DG to the offsite source can be made and the DG can 1 be returned to ready to load status when offsite power is restored. It also ensures that the autostart logic is reset to allow the DG to reload if a E

subsequent loss of offsite power occurs. The DG is considered to be in 1 E

ready to load status when the DG is at rated speed and voltage, the output breaker is open and can receive an autoclose signal on bus undervoltage, and the load sequence timers are reset.

[ The Frequency of [ 18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(6), and takes into consideration unit conditions required to perform the Surveillance. 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-31 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

1, 2, 3, or 4 This restriction from normally performing the Surveillance in MODE 1 or 2 1 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

INSERT 23 16

[ SR 3.8.1.17 5 E

Demonstration of the test mode override ensures that the DG availability 1 under accident conditions will not be compromised as the result of testing E

and the DG will automatically reset to ready to load operation if a LOCA 1 actuation signal is received during operation in the test mode. Ready to load operation is defined as the DG running at rated speed and voltage 1 E

with the DG output breaker open. These provisions for automatic switchover are required by IEEE-308 (Ref. 13), paragraph 6.2.6(2).

INSERT 24 The requirement to automatically energize the emergency loads with 11 offsite power is essentially identical to that of SR 3.8.1.12. The intent in 5 the requirement associated with SR 3.8.1.17.b is to show that the 16 E

emergency loading was not affected by the DG operation in test mode. In 1 lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

[ The [ 18 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(8), takes into 2

consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-32 Rev. 5.0 1

B 3.8.1 1

INSERT 23 In addition, because each unit requires three EDGs to be OPERABLE (two from the associated unit and one from the opposite unit) clarification is added stating that the MODE restriction on the performance of this test applies only to the associated units' EDGs.

1 INSERT 24 included in Regulatory Guide 1.108 (Ref. 9), Regulatory Position C.2.a.(8)

Insert Page B 3.8.1-32

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

OR 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

1, 2, 3, or 4 This restriction from normally performing the Surveillance in MODE 1 or 2 1 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. ] Credit may be 2 taken for unplanned events that satisfy this SR.

INSERT 25 17 SR 3.8.1.18 5 Under accident [ and loss of offsite power] conditions loads are 2 sequentially connected to the bus by the [ automatic load sequencer] . The sequencing logic controls the permissive and starting signals to motor E

breakers to prevent overloading of the DGs due to high motor starting 1 currents. The [ 10] % load sequence time interval tolerance ensures that 2 E

sufficient time exists for the DG to restore frequency and voltage prior to 1 applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-33 Rev. 5.0 1

B 3.8.1 1

INSERT 25 In addition, because each unit requires three EDGs to be OPERABLE (two from the associated unit and one from the opposite unit) clarification is added stating that the MODE restriction on the performance of this test applies only to the associated units' EDGs.

Insert Page B 3.8.1-33

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The Frequency of [ 18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(2), takes into consideration unit conditions required to perform the Surveillance, and is 2 intended to be consistent with expected fuel cycle lengths.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

1, 2, 3, or 4 This restriction from normally performing the Surveillance in MODE 1 or 2 1 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

INSERT 26

REVIEWERS NOTE-----------------------------------

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as 4 applicable:

a. Performance of the SR will not render any safety system or component inoperable, Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-34 Rev. 5.0 1

B 3.8.1 1

INSERT 26 In addition, because each unit requires three EDGs to be OPERABLE (two from the associated unit and one from the opposite unit) clarification is added stating that the MODE restriction on the performance of this test applies only to the associated units' EDGs.

Insert Page B 3.8.1-34

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and 4
c. Performance of the SR, or failure of the SR, will not cause, or result in, an AOO with attendant challenge to plant safety systems.

18 SR 3.8.1.19 5 E

In the event of a DBA coincident with a loss of offsite power, the DGs are 1 required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.

E This Surveillance demonstrates the DG operation, as discussed in the 1 10 Bases for SR 3.8.1.11, during a loss of offsite power actuation test signal 5 in conjunction with an ESF actuation signal. In lieu of actual E

demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is 1 acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

[ The Frequency of [ 18 months] takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length of [ 18 months] . 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR is modified by two Notes. The reason for Note 1 is to minimize E

wear and tear on the DGs during testing. For the purpose of this testing, 1 the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained E

consistent with manufacturer recommendations for DGs. The reason for 1 Note 2 is that the performance of the Surveillance would remove a Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-35 Rev. 5.0 1

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally 1, 2, 3, or 4 performing the Surveillance in MODE 1 or 2 is further amplified to allow 1 portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.

INSERT 27 19 SR 3.8.1.20 5 E

This Surveillance demonstrates that the DG starting independence has 1 not been compromised. Also, this Surveillance demonstrates that each E

engine can achieve proper speed within the specified time when the DGs 1 are started simultaneously.

[ The 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 10). 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-36 Rev. 5.0 1

B 3.8.1 1

INSERT 27 In addition, because each unit requires three EDGs to be OPERABLE (two from the associated unit and one from the opposite unit) clarification is added stating that the MODE restriction on the performance of this test applies only to the associated units' EDGs.

Insert Page B 3.8.1-36

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note. The reason for the Note is to minimize wear E

on the DG during testing. For the purpose of this testing, the DGs must be 1 started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations.

1967 proposed GDC 39, REFERENCES 1. 10 CFR 50, Appendix A, GDC 17. Emergency Power for Engineered 1

U Safety Features

2. FSAR, Chapter [8]. 1 2 2, December 1979
3. Regulatory Guide 1.9, Rev. 3. 1 U
4. FSAR, Chapter [6]. 1 2 U 14
5. FSAR, Chapter [15]. 1 2
6. Regulatory Guide 1.93, Rev. 0, December 1974.
7. Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," July 2, 1984.
8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.
9. 10 CFR 50, Appendix A, GDC 18. 1 9
10. Regulatory Guide 1.108, Rev. 1, August 1977. 1 10 1, October 1979
11. Regulatory Guide 1.137, Rev. [ ], [date]. 2 11
12. ASME Code for Operation and Maintenance of Nuclear Power Plants. "Turkey Point Unit 3 and Unit 4 License Amendment 12 215 and 209, dated August 8, 2001.
13. IEEE Standard 308-1978. 1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.1-37 Rev. 5.0 1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.1 BASES, AC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Action B and D have been added to include actions contained in the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) that are not included in ISTS. These actions have been added and the subsequent Actions relabeled.
4. The Reviewer's Note is deleted because it is not meant to be retained in the plant specific Improved Technical Specifications (ITS).
5. ISTS includes two similar Surveillance Requirements (SRs)for Emergency Diesel Generator (EDG) starts, SR 3.8.1.2 and SR 3.8.1.7. The major difference between the two surveillances is that SR 3.8.1.7 includes a time requirement for the EDG to reach a voltage and frequency requirement. The ISTS Bases state that because ISTS SR 3.8.1.7 requires a 10 second start, it is more restrictive than ISTS SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2. The PTN CTS does not include an SR for an EDG start without a time requirement but only the timed EDG start. ISTS SR 3.8.1.2 has been deleted with the subsequent SRs renumbered.
6. Changes are made to be consistent with changes made to the Specification.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES - OPERATING There are no specific No Significant Hazards Considerations for this Specification.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

ATTACHMENT 2 ITS 3.8.2, AC SOURCES - SHUTDOWN

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS A01 ITS 3.8.2 A.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION LCO 3.8.2 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

qualified circuit A02 LCO 3.8.2 a. One startup transformer and associated circuits, or an alternate circuit, between the offsite transmission network and the 4160 volt bus, A or B, and onsite Class 1E AC electrical power LCO 3.8.2 b. One diesel generator with: distribution subsystem(s) required by LCO 3.8.10, " Distribution Systems - Shutdown" LCO 3.8.2 1) For Unit 3 (3A or 3B)

SR 3.8.2.1 A skid-mounted fuel tank and a day fuel tank, with an OPERABLE solenoid valve to permit gravity flow from the day tank to the skid mounted tank, with the two tanks together containing a minimum of 2000 gallons of fuel oil LCO 3.8.2 For Unit 4 (4A or 4B)

See ITS SR 3.8.2.1 A day fuel tank containing a minimum volume of 230 gallons of fuel 3.8.3

2) A fuel storage system containing a minimum volume of fuel of 38,000 gallons (Unit 3).

34,700 gallons (Unit 4)**

SR 3.8.2.1 3) An associated fuel transfer pump**

4) For Unit 3 only, lubricating oil storage containing a minimum volume of 120 gallons of lubricating oil
5) For Unit 3 only capability to transfer lubricating oil from storage to the diesel generator unit and
6) Energized MCC bus (as identified by Specification 3.8.1.1.b.). See ITS See ITS 3.8.3 3.8.10 Applicability APPLICABILITY: MODES 5* and 6*.

During movement of irradiated fuel assemblies ACTION: M01 Add proposed ACTIONS Note Required NOTE: Enter the ACTION of LCO 3.8.3.2, Onsite Power Distribution - Shutdown, with one required train Action A.1 Note L05 de-energized as a result of inoperable offsite circuit.

Action A, With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all Action B L01 operations involving CORE ALTERATIONS, positive reactivity changes, movement of irradiated fuel, or crane operation with loads over the fuel storage pool, and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the Reactor Coolant System through a greater than or equal to 2.2 square inch vent. In addition, when in MODE 5 with the reactor M02 coolant loops not filled, or in MODE 6 with the water level less than 23 feet above the reactor vessel flange, RA A.2.3 RA B.3 immediately initiate corrective action to restore the required sources to OPERABLE status as soon as possible L02 and increase RCS inventory as soon as possible.

Add proposed Required Action A.1 and Completion Time LA01 See ITS

  • CAUTION - If the opposite unit is in MODES 1. 2. 3, or 4 see Specification 3.8.1.1 3.8.3
    • A temporary Class III fuel storage system containing a minimum volume of 38,000 gallons of fuel oil may be used for up to 10 days during the performance of Surveillance Requirement 4.8.1.1.2i.1 for the Unit 3 storage tank while Unit 3 is in Modes 5, 6, or defueled. If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively.

TURKEY POINT - UNITS 3 & 4 3/4 8-11 AMENDMENT NOS. 287 AND 281 Page 1 of 2

ITS A01 ITS 3.8.2 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS SR 3.8.2.1 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the requirements of Specifications 4.8.1.1.1.a and 4.8.1.1.2 (except for Specification 4.8.1.1.2a.5).

L03 Add proposed SR 3.8.2.1 Note L04 TURKEY POINT - UNITS 3 & 4 3/4 8-12 AMENDMENT NOS. 181 AND 175 Page 2 of 2

DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.1.2.a states that one startup transformer and associated circuits, or an alternate circuit, between the offsite transmission network and the 4160-volt bus, A or B, shall be OPERABLE. ITS 3.8.2 states that one qualified circuit, or an alternate circuit, between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by Limiting Condition for Operation (LCO) 3.8.10, "Distribution Systems - Shutdown" must be OPERABLE. This changes the CTS by defining the startup transformer and associated circuits as the "qualified circuit" and directing the user to ITS 3.8.10 instead of listing the buses the qualified circuit is to be connected to.

This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.1.2 is applicable during MODES 5 and 6. ITS 3.8.2 is applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies. In addition, a Note has been added to the ACTIONS of ITS 3.8.2 that states LCO 3.0.3 is not applicable. This changes the CTS by requiring the AC Sources to be OPERABLE under more conditions than is currently required.

The purpose of CTS 3.8.1.2 is to ensure that sufficient AC Sources are available to mitigate the consequences of an analyzed event during shutdown modes.

This change provides an explicit requirement that the AC Sources must be OPERABLE during the movement of irradiated fuel assemblies. The movement of irradiated fuel assemblies may occur during MODE 5 or 6; however, the operations could also occur while the unit is MODE 1, 2, 3, or 4 if moving fuel only in the spent fuel pool. CTS 3.8.1.1 (ITS 3.8.1) does not provide the appropriate compensatory actions during movement of irradiated fuel assemblies. The movement of irradiated fuel assemblies should be suspended immediately when the AC Sources are not available consistent with the immediate actions in the CTS 3.8.1.2 ACTION. Entering LCO 3.0.3 while the unit is in MODE 5 or 6 provides no actions as LCO 3.0.3 is not applicable in MODE 5 or 6. Entering LCO 3.0.3 while in Mode 1, 2, 3, or 4 in lieu of ceasing movement of irradiated fuel would result in an unnecessary plant transient and would not place the unit in a safer condition. This change is acceptable because the Turkey Point Unit 3 and Unit 4 Page 1 of 7

DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN proposed Applicability is consistent with the Applicability in the AC Distribution System - Shutdown Specification (CTS 3.8.2.2 and ITS 3.8.10). This change is designated as more restrictive because the Applicability of the Specification has been expanded.

M02 The CTS 3.8.1.2 Action requires, in part, that with less than the minimum required A.C. electrical power sources OPERABLE that when in MODE 5 with the reactor coolant loops not filled, or in MODE 6 with the water level less than 23 feet above the reactor vessel flange to increase RCS inventory as soon as possible. ITS 3.8.2 Required Actions A.2.3 and B.3 require the immediate initiation of action to restore the required AC Sources to OPERABLE status. This changes the CTS by expanding the Action requirement to restore the inoperable AC Sources to OPERABLE status regardless of fill status of the reactor coolant loops or the water level above the top of reactor vessel flange.

The purpose of ITS 3.8.2 Required Actions A.2.3 and B.3 is to promptly initiate action to restore the LCO requirements. When a required offsite circuit or one required EDG is inoperable, the actions imposed by the CTS 3.8.1.2 ACTION do not necessarily place the unit in a MODE or other specified condition in which CTS 3.8.1.2 is not applicable. Therefore, proposed ITS 3.8.2 Required Actions A.2.3 and B.3 are being expanded to apply in all plant configurations in MODES 5 and 6. When in MODE 5 with the reactor coolant loops filled and MODE 6 with water level 23 ft above the reactor vessel flange, at least one shutdown cooling loop is required to be OPERABLE and in operation and two trains of the Control Room Emergency Ventilation System are required to be OPERABLE during movement of irradiated fuel assemblies. Therefore, AC Sources are, at a minimum, required to be OPERABLE to support these required systems to avoid immediate difficulty, assuming either a loss of all offsite power or a loss of all onsite emergency diesel generator (EDG) power. These additional restrictions will ensure action is immediately taken to restore compliance with the LCO requirements. In addition, ITS 3.4.8, "RCS Loops - MODE 5, Loops not Filled,"

and ITS 3.9.5, "RHR and Coolant Circulation - Low Water Level," provide appropriate Required Actions when their associated LCO is not met due to a loss of an AC source causing a loss of an RHR pump. This change is designated as more restrictive because the CTS Required Actions are expanded to apply to all plant configurations in MODES 5 and 6 and during movement of irradiated fuel assemblies.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.1.2, Applicability Footnote

  • states "CAUTION

- If the opposite unit is in MODES 1, 2, 3, or 4 see Specification 3.8.1.1." ITS 3.8.2, Applicability does not include this Footnote. This changes the CTS by Turkey Point Unit 3 and Unit 4 Page 2 of 7

DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN removing the procedural details cautioning the operator to refer to CTS Specification 3.8.1.1 (ITS 3.8.1) for the opposite unit if the opposite unit is in MODES 1, 2, 3, or 4.

The removal of these details for performing actions from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements for AC Sources -

Operating (ITS 3.8.1) that continues to assure protection of public health and safety. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.

This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.1.2 ACTION requires, in part, that with less than the minimum required AC electrical power sources OPERABLE, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the Reactor Coolant System (RCS) through a greater than or equal to 2.2 square inch vent. In addition, when in MODE 5 with the reactor coolant loops not filled, or in MODE 6 with the water level less than 23 feet above the reactor vessel flange, increase RCS inventory as soon as possible. ISTS 3.8.2 does not include this Required Action. ITS LCO 3.4.12, "Low Temperature Overpressure Protection (LTOP) System," provides requirements for RCS pressure relief when in MODES 4, 5, or 6, with limitations including a Required Action to depressurize and establish an RCS vent of 2.2 square inches within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if the other pressure relief methods are incapable of limiting pressure. This changes the CTS by relying on ITS LCO 3.4.12 to provide the Required Actions and allowing a longer Completion Time to depressurize the RCS and establish a 2.2 square inch RCS vent.

The purpose of CTS 3.8.1.2 ACTION is to provide remedial actions to be taken in response to the loss of a required DC train while in MODE 5 or 6. One of these remedial actions is to depressurize and vent the RCS through at least a 2.2 square inch vent. This change is acceptable because the CTS 3.8.1.2 ACTION to depressurize and vent the RCS is duplicative of the ITS LCO 3.4.12 Required Action to depressurize and vent the RCS. In addition, ITS 3.4.12 Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the allowed Completion Time. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

Turkey Point Unit 3 and Unit 4 Page 3 of 7

DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN L02 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.2 ACTION requires the suspension of certain activities when the required AC Source is inoperable.

ITS 3.8.2 provides an alternate Required Action (ITS 3.8.2, Required Action A.1) that allows the declaration of affected required feature(s) with no offsite power available inoperable instead of requiring the specified activities to be suspended.

This changes the CTS by allowing the affected required feature(s) with no offsite power available to be declared inoperable instead of suspending the specified activities.

The purpose of CTS 3.8.1.2 is to ensure the appropriate offsite circuit is OPERABLE. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the repair period. This changes the CTS by allowing the affected required feature(s) with no offsite power available to be declared inoperable instead of suspending specified activities (i.e., movement of irradiated fuel assemblies). Because the ITS 3.8.2 circuit OPERABILITY requirements are proposed to require supplying power to all required electrical power distribution subsystems, if one or more subsystems are not powered by an offsite circuit, that circuit is inoperable.

Conservative actions can be assured if all required equipment with offsite power is declared inoperable and the associated ACTIONS of the individual equipment is taken (ITS 3.8.2, Required Action A.1). This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L03 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.1.2 requires the AC electrical power sources to be demonstrated OPERABLE by the performance of each of the Surveillance Requirements (SRs) of 4.8.1.1.1.a and 4.8.1.1.2 (except for Specification 4.8.1.1.2a.5). ITS SR 3.8.2.1 has included a similar allowance in the Note to SR 3.8.2.1; however, additional ITS SRs are exempt from being required to be performed. ITS SR 3.8.2.1 Note states the following SRs are not required to be performed:

SR 3.8.1.2, SR 3.8.1.8 through SR 3.8.1.10, SR 3.8.1.12 through SR 3.8.1.15, and SR 3.8.1.17. ITS 3.8.1.2 is CTS 4.8.1.1.2a.5. This changes the CTS by not requiring the performance of CTS 4.8.1.1.2g.2 (ITS SR 3.8.1.8),

CTS 4.8.1.1.2g.3 (ITS SR 3.8.1.9), CTS 4.8.1.1.2g.4 (ITS SR 3.8.1.10),

CTS 4.8.1.1.2g.6)c (ITS SR 3.8.1.12), CTS 4.8.1.1.2g.7 (ITS SR 3.8.1.13),

CTS 4.8.1.1.2g.7 (ITS SR 3.8.1.14), CTS 4.8.1.1.2g.9 (ITS SR 3.8.1.15), and CTS 4.8.1.1.2g.12 (ITS SR 3.8.1.17).

The purpose of CTS 3.8.1.2 is to ensure the appropriate AC Sources are demonstrated to be OPERABLE. This change is acceptable because the new Surveillance Acceptance Criteria provides an acceptable level of equipment reliability. Currently CTS 4.8.1.1.2a.5 (ITS 3.8.1.2) is not required to be performed (however it must be met). CTS 4.8.1.1.2g.2 (ITS SR 3.8.1.8) is the Turkey Point Unit 3 and Unit 4 Page 4 of 7

DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN emergency diesel generator (EDG) single largest load reject test, CTS 4.8.1.1.2g.3 (ITS SR 3.8.1.9) is the EDG full load reject test, CTS 4.8.1.1.2g.4 (ITS SR 3.8.1.10) is the EDG start on a loss of offsite power test, CTS 4.8.1.1.2g.6)c (ITS SR 3.8.1.12) demonstrates the EDG noncritical protective functions are bypassed on a loss of voltage signal concurrent with an Engineered Safety Feature (ESF) actuation test signal, CTS 4.8.1.1.2g.7 (ITS SR 3.8.1.13) is the EDG 24-hour run test, CTS 4.8.1.1.2g.7 (ITS SR 3.8.1.14) is the EDG hot restart test, CTS 4.8.1.1.2g.9 (ITS SR 3.8.1.15) ensures manual synchronization and automatic load transfer from the EDG to the offsite source can be made and the EDG can be returned to ready to load status when offsite power is restored, and CTS 4.8.1.1.2g.12 (ITS SR 3.8.1.17) is a test of the individual load sequence timers.

These tests normally require the EDG to be paralleled with offsite power. This condition (one of two required EDGs and the only required offsite source connected) presents a significant risk of a single fault resulting in station blackout. The NRC has previously recognized this in the exception stated in CTS 4.8.1.2. To consistently address this concern and to avoid potential conflict with the Technical Specifications, the Surveillances that would require an EDG to be connected to the offsite source or would require disconnection of the required offsite circuit and de-energization of required buses are excepted from performance requirements. The exception does not remove the requirement for the EDGs to be capable of performing the onsite power source function. The exception only removes the requirement to demonstrate the capability while that source of power is being relied on to meet the supporting LCO. This change is acceptable because the EDG must still be capable of supply required MODE 5 and 6 loads if needed, but actual SR performance is not required during periods when an EDG and the offsite circuit are required to be OPERABLE. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L04 (Category 5 - Deletion of Surveillance Requirements) CTS 4.8.1.2 requires the AC electrical power sources to be demonstrated OPERABLE by the performance of SRs 4.8.1.1.1.a and 4.8.1.1.2 (except for Specification 4.8.1.1.2a.5). ITS SR 3.8.2.1 is exempting additional SRs, providing a list of SRs that are not applicable. ITS SR 3.8.2.1 states that for AC sources required to be OPERABLE, the SRs of Specification 3.8.1, "AC Sources - Operating," except SR 3.8.1.7, SR 3.8.1.11, SR 3.8.1.16, SR 3.8.1.18, and SR 3.8.1.19, are applicable. This changes the CTS by not requiring CTS 4.8.1.1.1.b (ITS SR 3.8.1.7), CTS 4.8.1.1.2g.5) (ITS SR 3.8.1.11), CTS 4.8.1.1.2g.10) (ITS SR 3.8.1.16), CTS 4.8.1.1.2g.6).a and b (ITS SR 3.8.1.18), and CTS 4.8.1.1.2h (ITS SR 3.8.1.19) to be met.

The purpose of CTS 3.8.1.2 is to ensure the appropriate AC Sources are demonstrated OPERABLE. This change is acceptable because the SRs are not necessary to verify that the equipment used to meet the LCO can perform its required functions. Thus, appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. This change deletes certain Surveillances from being required to be met. These Surveillances are CTS 4.8.1.1.1.b (ITS Turkey Point Unit 3 and Unit 4 Page 5 of 7

DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN SR 3.8.1.7), manual transfer of AC power sources, CTS 4.8.1.1.2g.5 (ITS SR 3.8.1.11), the ESF actuation signal EDG start test, CTS 4.8.1.1.2g.10 (ITS SR 3.8.1.16), ESF actuation signal overrides the test mode, CTS 4.8.1.1.2g.a and b (ITS SR 3.8.1.18), ESF concurrent with loss of offsite power signal test, and CTS 4.8.1.1.2h (ITS SR 3.8.1.19) the simultaneous EDG start test. ITS SR 3.8.1.11 and ITS SR 3.8.1.17 are not required to be met because the ESF signal is not required to be OPERABLE in the MODE 5 or 6. The CTS and ITS also do not require the Emergency Core Cooling System (ECCS) subsystem(s) to be OPERABLE in MODE 5 and 6. The EDGs are required to support the equipment powered from the 4160 V buses. However, when the ECCS subsystem(s) are not required to be OPERABLE, then there is no reason to require the EDG to auto-start on an ESF actuation signal. In addition, the ESF actuation signal is only an anticipatory start signal; the EDGs are only needed during a Design Basis Accident (DBA) if a loss of offsite power occurs concurrently. The EDGs are also required to start if a loss of offsite power occurs. The requirement to auto-start the required EDG(s) on a loss of offsite power signal is being maintained in the ITS (ITS SR 3.8.1.10). Thus, under these conditions (associated ECCS subsystem(s) not required to be OPERABLE), there is no reason to require the EDGs to be capable of automatically starting on an ESF actuation signal (either by itself or concurrent with a loss of offsite power signal). This change is designated as less restrictive because Surveillances that are required in CTS will not be required in the ITS.

L05 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.2 ACTION specifies the compensatory action for an inoperable required AC Source while in MODES 5 and 6. One of the compensatory actions is the suspension of CORE ALTERATIONS. Under similar conditions, ITS 3.8.2 does not require suspension of CORE ALTERATIONS. This changes the CTS by deleting the requirement to suspend CORE ALTERATIONS when a required AC source is inoperable.

The purpose of the CTS 3.8.1.2 ACTION to suspend CORE ALTERATIONS is to minimize the possibility of an event that may need the AC source to mitigate the consequences of the event. CORE ALTERATION is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel." CORE ALTERATIONS only occur when the reactor vessel head is removed - it only applies in MODE 6. There is only one accident considered during MODE 6 that involves a CORE ALTERATION: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building. Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, will not prevent or impair the mitigation of a fuel handling accident. ITS 3.8.2 retains the requirement to suspend movement of irradiated fuel assemblies in ITS 3.8.2 Required Action A.2.1 (for an inoperable required offsite circuit) and Required Action B.1 (for one or more inoperable required EDG(s)). Therefore, because the only CORE ALTERATION analyzed in the safety analysis and potentially affected by a loss of an AC source is covered by the ITS Required Actions, deletion of the term "CORE ALTERATIONS" is acceptable. Additionally, CORE ALTERATIONS that R2 may be capable of damaging a fuel assembly prior to the 72-hour decay period is Turkey Point Unit 3 and Unit 4 Page 6 of 7

DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN improbable because the physical time required to perform plant shutdown, cooldown, depressurize the Reactor Coolant System, and the additional R2 operations required to expose the irradiated fuel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Turkey Point Unit 3 and Unit 4 Page 7 of 7

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown 3.8.1.2 LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

, or an alternate circuit, 3.8.1.2.a a. One qualified circuit between the offsite transmission network and 1 the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown" and emergency EDG 3.8.1.2.b b. One diesel generator (DG) capable of supplying one train of the 1 onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

Applicability APPLICABILITY: MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies. 2 ACTIONS

NOTE-----------------------------------------------------------

DOC M01 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME Action A. One required offsite -------------------NOTE--------------------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.

OR Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.2-1 Rev. 5.0 1

AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A.2.1 Suspend movement of Immediately

[recently] irradiated fuel 2 assemblies.

AND DOC L01 A.2.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.3 Initiate action to restore Immediately Action required offsite power circuit to OPERABLE status.

E Action B. One required DG B.1 Suspend movement of Immediately 1 DOC L01 inoperable. [recently] irradiated fuel 2 assemblies.

AND DOC L01 B.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND Action B.3 Initiate action to restore Immediately EDG required DG to OPERABLE 1 status.

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.2-2 Rev. 5.0 1

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.1.2 SR 3.8.2.1 ------------------------------NOTE------------------------------

2 The following SRs are not required to be performed:

8 SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, 10 SR 3.8.1.13 through SR 3.8.1.16, and 3 12

[SR 3.8.1.18]. 15 2 17 For AC sources required to be OPERABLE, the SRs In accordance 7

of Specification 3.8.1, "AC Sources - Operating," with applicable except SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.17, 16 SRs 3 11 SR 3.8.1.19, and SR 3.8.1.20, are applicable.

18 19 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.2-3 Rev. 5.0 1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Changes are made to match the change in Surveillance Requirement (SR) numbers from the SRs in Limiting Condition for Operation (LCO) 3.8.1.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

AC Sources - Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources - Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources - Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 5 and 6 SAFETY and during movement of [recently] irradiated fuel assemblies ensures 2 ANALYSES that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling recently irradiated fuel. Due to radioactive decay, AC electrical power is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)]. 2 In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single because failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis 4 Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of result occurrence being significantly reduced or eliminated, and in minimal 4 consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO 1 for required systems.

During MODES 1, 2, 3, and 4, various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities must be conducted provided an acceptable level of risk is not exceeded. During MODES 5 and 6, performance of a Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.2-1 Rev. 5.0 1

AC Sources - Shutdown B 3.8.2 BASES APPLICABLE SAFETY ANALYSES (continued) significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and 4 administratively controlled. Relaxations from MODE 1, 2, 3, and 4 LCO requirements are acceptable during shutdown modes based on:

a. The fact that time in an outage is limited. This is a risk prudent goal 4 as well as a utility economic consideration.
b. Requiring appropriate compensatory measures for certain conditions.

These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operating MODE analyses, or both.

c. Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.
d. Maintaining, to the extent practical, the ability to perform required functions (even if not meeting MODE 1, 2, 3, and 4 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability to support systems necessary to avoid immediate difficulty, emergency assuming either a loss of all offsite power or a loss of all onsite diesel 1 EDG generator (DG) power.

The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO One offsite circuit capable of supplying the onsite Class 1E power distribution subsystem(s) of LCO 3.8.10, "Distribution Systems -

Shutdown," ensures that all required loads are powered from offsite associated EDG power. An OPERABLE DG, associated with a distribution system train 1 INSERT 1 required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit EDG and DG ensures the availability of sufficient AC sources to operate the 1 unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling 2 recently irradiated fuel]).

The qualified offsite circuit must be capable of providing three phases of 1 AC power, maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the Engineered Safety Feature (ESF) bus(es). Qualified offsite circuits are those that are described in the FSAR and are part of the licensing basis for the unit. 1 Bases for LCO 3.8.1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.2-2 Rev. 5.0 1

ITS 3.8.2 1

INSERT 1 (Unit 3 either 3A or 3B and Unit 4 either 4A or 4B)

Insert Page B 3.8.2-2

AC Sources - Shutdown B 3.8.2 BASES LCO (continued)

INSERT 2

[ Offsite circuit #1 consists of Safeguards Transformer B, which is supplied from Switchyard Bus B, and is fed through breaker 52-3 powering the ESF transformer XNB01, which, in turn, powers the #1 ESF bus through its normal feeder breaker. The second offsite circuit consists of the 2 Startup Transformer, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201 powering the ESF transformer, which, in turn, powers the #2 ESF bus through its normal feeder breaker. ]

EDG The DG must be capable of starting, accelerating to rated speed and 1 voltage, and connecting to its respective ESF bus on detection of bus 15 undervoltage. This sequence must be accomplished within [10] seconds. 2 EDG The DG must be capable of accepting required loads within the assumed 1 loading sequence intervals, and continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with the 1 EDG engine hot and DG in standby at ambient conditions.

Proper sequencing of loads, including tripping of nonessential loads, is a EDG required function for DG OPERABILITY. 1

[ In addition, proper sequencer operation is an integral part of offsite circuit 1 OPERABILITY since its inoperability impacts on the ability to start and maintain energized loads required OPERABLE by LCO 3.8.10. ] 1 It is acceptable for trains to be cross tied during shutdown conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 and during movement of [recently] irradiated fuel assemblies provide 2 assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core,
b. Systems needed to mitigate a fuel handling accident [involving 2 handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)] are available, 2
c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.2-3 Rev. 5.0 1

ITS 3.8.2 2

INSERT 2 LCO 3.8.2 requires, in part, that a qualified circuit or an alternate circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown" be OPERABLE. The qualified circuit is one of the two startup transformers, one for each unit, connected to the 240 kV buses on their primary sides and have two secondary windings at 4.16 kV that are connected to 4.16 kV buses A or B. An alternate circuit is one that supplies power from the offsite transmission network to 4.16 kV bus A or B. The C bus transformers, through the C buses, serve the unit during startup, shutdown, and after a unit trip; or energizing the Auxiliary Transformer or Startup Transformer with the Main Transformer aligned for backfeed are an example of an alternate circuit that can be connected to bus A or B.

Insert Page B 3.8.2-3

AC Sources - Shutdown B 3.8.2 BASES APPLICABILITY (continued)

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1. If the opposite unit is in MODES 1, 2, 3, or 4, requirements 1 R2 for the opposite unit are provided in LCO 3.8.1.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1 An offsite circuit would be considered inoperable if it were not available to one required ESF train. Although two trains are required by LCO 3.8.10, the one train with offsite power available may be capable of supporting sufficient required features to allow continuation of [recently] irradiated 2 fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

A.2.1, A.2.2, A.2.3, B.1, B.2, and B.3 With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently EDG conservative actions is made. With the required DG inoperable, the 1 minimum required diversity of AC power sources is not available. It is, therefore, required to suspend movement of [recently] irradiated fuel 2 assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.2-4 Rev. 5.0 1

AC Sources - Shutdown B 3.8.2 BASES ACTIONS (continued) concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System's ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are modified by a Note to indicate that when Condition A is entered with no AC power to any required ESF bus, the ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.10 would provide the appropriate restrictions for the situation involving a de-energized train.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for 7

ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 3, and 4. SR 3.8.1.8 is not required to be met since only one offsite 11 3 circuit is required to be OPERABLE. SR 3.8.1.12 and SR 3.8.1.19 are 18 not required to be met because the ESF actuation signal is not required to 16 be OPERABLE. SR 3.8.1.17 is not required to be met because the 3 EDG required OPERABLE DG(s) is not required to undergo periods of being 1 19 synchronized to the offsite circuit. SR 3.8.1.20 is excepted because 3 EDG starting independence is not required with the DG(s) that is not required 1 to be operable.

This SR is modified by a Note. The reason for the Note is to preclude EDG requiring the OPERABLE DG(s) from being paralleled with the offsite 1 power network or otherwise rendered inoperable during performance of SRs, and to preclude deenergizing a required 4160 V ESF bus or Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.2-5 Rev. 5.0 1

AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE REQUIREMENTS (continued) disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the EDG required circuit and the DG. It is the intent that these SRs must still be 1 capable of being met, but actual performance is not required during EDG periods when the DG and offsite circuit is required to be OPERABLE. 1 Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

REFERENCES None.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.2-6 Rev. 5.0 1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.2 BASES, AC SOURCES - SHUTDOWN

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Changes have been made to be consistent with changes made to the Specifications.
4. Editorial/grammatical error corrected.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.2, AC SOURCES - SHUTDOWN There are no specific No Significant Hazards Considerations for this Specification.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

ATTACHMENT 3 ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS A01 ITS 3.8.3 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING Add proposed LCO 3.8.3 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.3 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two startup transformers and their associated circuits, and See ITS 3.8.1
b. Three separate and independent diesel generators* including,
1) For Unit 3, two (3A and 3B); for Unit 4, one (3A or 3B) each with:

a) A separate skid-mounted fuel tank and a separate day fuel tank with an OPERABLE solenoid valve to permit gravity flow from the day tank to the skid mounted tank, and with the two tanks together containing a minimum of 2000 gallons of fuel oil.

SR 3.8.3.1 b) A common Fuel Storage System containing a minimum volume of 38,000 gallons of fuel,** a da LA01 c) A separate fuel transfer pump,**

SR 3.8.3.2 d) Lubricating oil storage containing a minimum volume of 120 gallons of lubricating oil, See ITS LA02 3.8.9 e) Capability to transfer lubricating oil from storage to the diesel generator unit, and f) Energized MCC bus (MCC 3A vital section for EDG 3A, MCC 3K for EDG 3B).

2) For Unit 3, one (4A or 4B); for Unit 4, two (4A and 4B) each with: See ITS 3.8.1 a) A separate day fuel tank containing a minimum volume of 230 gallons of fuel, SR 3.8.3.1 b) A separate Fuel Storage System containing a minimum volume of 34,700 gallons of fuel, a da LA01 c) A separate fuel transfer pump, and d) Energized MCC bus (MCC 4J for EDG 4A, MCC 4K for EDG 4B). See ITS 3.8.9 See ITS 3.8.1
  • Whenever one or more of the four EDG's is out-of-service, ensure compliance with the EDG requirements specified in Specifications 3.5.2 and 3.8.2.1.

tank cleaning A03 LCO 3.8.3

    • A temporary Class III fuel storage system containing a minimum volume of 38, 000 gallons of fuel oil may be Note used for up to 10 days during the performance of Surveillance Requirement 4.8.1.1.2i.1 for the Unit 3 storage tank while Unit 3 is in Modes 5, 6, or defueled. If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively.

M03 TURKEY POINT - UNITS 3 & 4 3/4 8-1 AMENDMENT NOS. 197 AND 191 Page 1 of 7

ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

Applicability APPLICABILITY: MODES 1, 2, 3, and 4. A02 When associated EDG is required to be OPERABLE ACTION:

See ITS NOTE: LCO 3.0.4.b is not applicable to diesel generators. 3.8.1

a. With one of two startup transformers or an associated circuit inoperable:
1. Demonstrate the OPERABILITY of the other startup transformer and its associated circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
2. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s), declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.
3. If the inoperable startup transformer is the associated startup transformer and became inoperable while the unit is in Mode 1:

a) Reduce THERMAL POWER to 30% RATED THERMAL POWER within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or b) Restore the inoperable startup transformer and associated circuits to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

4. If THERMAL POWER is reduced to 30% RATED THERMAL POWER within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or if the inoperable startup transformer is associated with the opposite unit, restore the startup transformer and its associated circuits to OPERABLE status within 30 days of the loss of OPERABILITY, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
5. If the inoperable startup transformer is the associated startup transformer and became inoperable while the unit was in MODE 2, 3, or 4, restore the startup transformer and its associated circuits to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units simultaneously.

Add proposed ACTIONS Note A04 Add proposed ACTION A L01 Add proposed ACTION B and SR 3.8.3.2 M01 Add proposed ACTION E and SR 3.8.3.4 M02 Add proposed ACTION F A05 TURKEY POINT - UNITS 3 & 4 3/4 8-2 AMENDMENT NOS. 287 AND 281 Page 2 of 7

ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

See ITS 3.8.1 ACTION (Continued)

f. With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two startup transformers and their associated circuits by performing the requirements of Specification 4.8.1.1.1a. within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore at least one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Restore all required diesel generators to OPERABLE status within 14 days from time of initial loss or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Action D g. Following the addition of the new fuel oil* to the Diesel Fuel Oil Storage Tanks, with one or more diesel generators with new fuel oil properties outside the required Diesel Fuel Oil Testing Program limits, restore the stored fuel oil properties to within the required limits within 30 days.

Action C h. With one or more diesel generators with stored fuel oil total particulates outside the required Diesel Fuel Oil Testing Program limits, restore the fuel oil total particulates to within the required limits within 7 days.

  • The properties of API Gravity, specific gravity or an absolute specific gravity; kinematic viscosity; clear SR 3.8.3.3 and bright appearance; and flash point shall be confirmed to be within the Diesel Fuel Oil Testing Program limits, prior to the addition of the new fuel oil to the Diesel Fuel Oil Storage Tanks.

TURKEY POINT - UNITS 3 & 4 3/4 8-4 AMENDMENT NOS. 287 AND 281 Page 3 of 7

ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS SURVEILLANCE REOUIREMENTS (Continued) 4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE*:

See ITS

a. In accordance with the Surveillance Frequency Control Program by: 3.8.1
1) Verifying the fuel volume in the day and skid-mounted fuel tanks (Unit 4-day tank only),

SR 3.8.3.1 2) Verifying the fuel volume in the fuel storage tank, See ITS SR 3.8.3.2 3) Verifying the lubricating oil inventory in storage, 3.8.1

4) Verifying the diesel starts and accelerates to reach a generator voltage and frequency of 3950-4350 volts and 60 + 0.6 Hz. In accordance with the Surveillance Frequency Control Program, these conditions shall be reached within 15 seconds after the start signal from normal conditions. For all other starts, warmup procedures, such as idling and gradual acceleration as recommended by the manufacturer may be used. The diesel generator shall be started for this test by using one of the following signals:

a) Manual, or b) Simulated loss-of-offsite power by itself, or c) Simulated loss-of-offsite power in conjunction with an ESF Actuation test signal, or d) An ESF Actuation test signal by itself.

5) Verifying the generator is synchronized, loaded** to 2300 - 2500 kW (Unit 3), 2650-2850 kW (Unit 4)***, operates at this loaded condition for at least 60 minutes and for Unit 3 until automatic transfer of fuel from the day tank to the skid mounted tank is demonstrated, and the cooling system is demonstrated OPERABLE.
6) Verifying the diesel generator is aligned to provide standby power to the associated emergency buses.

See ITS 3.8.1

  • All diesel generator starts for the purpose of these surveillances may be proceeded by a prelube period as recommended by the manufacturer.
    • May include gradual loading as recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized.
      • Momentary transients outside these load bands do not invalidate this test.

TURKEY POINT - UNITS 3 & 4 3/4 8-6 AMENDMENT NOS. 263 AND 258 Page 4 of 7

ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS See ITS SURVEILLANCE REQUIREMENTS (Continued) 3.8.1

b. Demonstrating that a fuel transfer pump starts automatically and transfers fuel from the storage system to the day tank, in accordance with the Surveillance Frequency Control Program;
c. In accordance with the Surveillance Frequency Control Program and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the day and skid-mounted fuel tanks (Unit 4-day tank only);

SR 3.8.3.5 d. In accordance with the Surveillance Frequency Control Program by checking for and removing accumulated water from the fuel oil storage tanks; SR 3.8.3.3 e. By verifying fuel oil properties of new fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.

SR 3.8.3.3 f. By verifying fuel oil properties of stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.

g. In accordance with the Surveillance Frequency Control Program, during shutdown (applicable to only the two diesel generators associated with the unit):
1) Deleted 2)* Verifying the generator capability to reject a load of greater than or equal to 392 kW without exceeding a frequency of 66.25 Hz. Within 2 seconds following the load rejection, the generator shall return to within 3950-4350 volts and frequency at 60 +/- 0.6 Hz; 3)* Verifying the generator capability to reject a load of greater than or equal to 2500 kW (Unit 3), 2874 kW (Unit 4) without tripping. The generator voltage shall return to less than or equal to 4784 volts within 2 seconds following the load rejection;
4) Simulating a loss-of-offsite power by itself, and:

a) Verifying deenergization of the emergency busses and load shedding from the emergency busses, and

b. Verifying the diesel starts on the auto-start signal, energizes the emergency busses with any permanently See ITS 3.8.1
  • For the purpose of this test, warmup procedures, such as idling, gradual acceleration, and gradual loading as recommended by the manufacturer may be used.

TURKEY POINT - UNITS 3 & 4 3/4 8-7 AMENDMENT NOS. 285 AND 279 Page 5 of 7

ITS A01 ITS 3.8.3 ELECTRICAL POWER SYSTEMS See ITS 3.8.1 SURVEILLANCE REQUIREMENTS (Continued)

h. In accordance with the Surveillance Frequency Control Program or after any modifications which could affect diesel generator interdependence by starting all required diesel generators simultaneously and verifying that all required diesel generators provide 60 +/- 0.6 Hz frequency and 3950-4350 volts in less than or equal to 15 seconds: and
i. In accordance with the Surveillance Frequency Control Program, by draining each fuel oil storage tank, removing the accumulated sediment and cleaning the tank.*

LA03

j. At least once per 10 years, for Unit 4 only, by performing a pressure test of those portions of the diesel fuel oil system designed to Section III, subsection ND of the ASME Code in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda.

4.8.1.1.3 Reports - (Not Used) tank cleaning A03 LCO 3.8.3

  • A temporary Class III fuel storage system containing a minimum volume of 38,000 gallons of fuel oil may be Note used for up to 10 days during the performance of Surveillance Requirement 4.8.1.1.2i for the Unit 3 storage tank while Unit 3 is in Modes 5, 6, or defueled. If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively.

TURKEY POINT - UNITS 3 & 4 3/4 8-10 AMENDMENT NOS. 263 AND 258 Page 6 of 7

ITS A01 ITS 3.8.3 A.C. SOURCES SHUTDOWN Add proposed LCO 3.8.3 A02 LIMITING CONDITION FOR OPERATION LCO 3.8.3 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One startup transformer and associated circuits, or an alternate circuit, between the offsite transmission network and the 4160 volt bus, A or B, and
b. One diesel generator with: See ITS 3.8.2
1) For Unit 3 (3A or 3B)

A skid-mounted fuel tank and a day fuel tank, with an OPERABLE solenoid valve to permit gravity flow from the day tank to the skid mounted tank, with the two tanks together containing a minimum of 2000 gallons of fuel oil For Unit 4 (4A or 4B)

A day fuel tank containing a minimum volume of 230 gallons of fuel SR 3.8.3.1 2) A fuel storage system containing a minimum volume of fuel of 38,000 gallons (Unit 3).

34,700 gallons (Unit 4)** a da LA01

3) An associated fuel transfer pump** See ITS 3.8.2 SR 3.8.3.2 4) For Unit 3 only, lubricating oil storage containing a minimum volume of 120 gallons of lubricating oil LA02
5) For Unit 3 only capability to transfer lubricating oil from storage to the diesel generator unit and
6) Energized MCC bus (as identified by Specification 3.8.1.1.b.). See ITS 3.8.10 Applicability APPLICABILITY: MODES 5* and 6*.

When associated EDG is required to be OPERABLE A02 ACTION:

NOTE: Enter the ACTION of LCO 3.8.3.2, Onsite Power Distribution - Shutdown, with one required train de-energized as a result of inoperable offsite circuit.

With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, movement of irradiated fuel, or crane operation with loads over the fuel storage pool, and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the Reactor Coolant System through a greater than or equal to 2.2 square inch vent. In addition, when in MODE 5 with the reactor coolant loops not filled, or in MODE 6 with the water level less than 23 feet above the reactor vessel flange, immediately initiate corrective action to restore the required sources to OPERABLE status as soon as possible and increase RCS inventory as soon as possible.

See ITS 3.8.2

  • CAUTION - If the opposite unit is in MODES 1. 2. 3, or 4 see Specification 3.8.1.1 tank cleaning A03
    • A temporary Class III fuel storage system containing a minimum volume of 38,000 gallons of fuel oil may be LCO 3.8.3 used for up to 10 days during the performance of Surveillance Requirement 4.8.1.1.2i.1 for the Unit 3 storage Note tank while Unit 3 is in Modes 5, 6, or defueled. If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively.

TURKEY POINT - UNITS 3 & 4 3/4 8-11 AMENDMENT NOS. 287 AND 281 Page 7 of 7

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS Limiting Condition for Operation (LCO) 3.8.1.1 and LCO 3.8.1.2 state the requirements for the AC Sources during operating and shutdown conditions, respectively. These requirements are used to form the LCO and Applicability for the ITS diesel fuel oil, lube oil, and starting air Specification. ITS LCO 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," states that the stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required Emergency Diesel Generator (EDG). The Applicability for this requirement is when the associated EDG is required to be OPERABLE. This changes the CTS by combining the requirements for diesel fuel oil and diesel lube oil and starting air subsystem into one Specification.

This change is acceptable because the current requirements are translated into ITS form with no technical changes. Diesel fuel oil, lube oil, and starting air subsystems are support systems for each EDG. The CTS and ITS maintain this relationship between the EDGs and the Diesel Fuel Oil System, EDG Lube Oil System, and Starting Air Subsystem. This change is designated as administrative because it does not result in a technical change to the CTS.

A03 CTS 3.8.1.1b.1)b requires a common Fuel Storage System containing a minimum volume of 38,000 gallons of fuel for the Unit 3 EDGs. CTS 3.8.1.1b.1)b, footnote ** modifies this requirement by stating, "A temporary Class III fuel storage system containing a minimum volume of 38,000 gallons of fuel oil may be used for up to 10 days during the performance of Surveillance Requirement 4.8.1.1.2i.1 for the Unit 3 storage tank while Unit 3 is in Modes 5, 6, or defueled. If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively." CTS 4.8.1.1.2i and CTS 3.8.1.2b.2 are modified by a similar Footnote. Although CTS 3.8.1.1b.1b footnote ** and CTS 3.8.1.2b.2 footnote ** identify the referenced Surveillance Requirement (SR) as 4.8.1.1.2i.1, the correct SR is 4.8.1.1.2i that was changed under PTN License Amendment 263 and 258 (ML15166A320) but missed for these two footnotes.

CTS 4.8.1.1.2i requires draining each fuel oil storage tank, removing the accumulated sediment, and cleaning the tank, and is proposed to be relocated (see DOC LA03). ITS 3.8.3 does not include this maintenance activity and is replacing the SR with the tank cleaning activity.

Turkey Point Unit 3 and Unit 4 Page 1 of 7

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR This change is acceptable because it does not change the technical requirements of the CTS. The CTS footnotes state that this allowance is for SR 4.8.1.1.2i that is to drain, remove sediment, and clean. Draining and the removal of sediment are activities including in tank cleaning; therefore, the activity of tank cleaning encompasses draining and removing sediment. The ITS requirements are consistent with the CTS requirements. This change is designated as administrative because the technical requirements of the specifications have not changed.

A04 CTS 3.8.1.1b requires three separate and independent EDGs to be operable and lists the subsystem parameters that must be included. CTS 3.8.1.2 states that one EDG must be OPERABLE and lists the subsystem parameters that must be included. ITS 3.8.3 Actions Table is modified by a Note indicating that separate Condition entry is allowed for each EDG. This changes the CTS by explicitly stating that the Action are directed towards a specific separate and independent EDG and have separate entry.

This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each required EDG subsystem. Complying with the Required Actions for one EDG subsystem may allow for continued operation, and subsequent EDG subsystems are governed by separate Condition entry and application of associated Required Actions. This change is designated as administrative because the technical requirements of the specifications have not changed.

A05 CTS 3.8.1.1b requires three separate and independent EDGs to be operable and lists the subsystem parameters that must be included. CTS 3.8.1.2 states that one EDG must be OPERABLE and lists the subsystem parameters that must be included. CTS LCO 3.0.2 requires that upon discovery of a failure to meet an LCO, the actions shall be met. ITS 3.8.3 provides an additional LCO associated with EDG fuel oil, lube oil, and starting air with associated surveillances defining when the LCO is met and Actions to take when the LCO is not met. ITS 3.8.3, ACTION F, is added to state under what condition associated with LCO 3.8.3 the associated EDG must be declared inoperable. This changes the CTS by provide a specific action for declaring the associated EDG inoperable.

This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each required EDG subsystem. Complying with the Required Actions allows for continued operation while responding to a condition that is still within the EDGs ability to function. If the Completion Time is exceeded or the parameter is not within limits for other reasons the ability to restore the support feature or the feature's ability to function are in question and the associated EDG is declared inoperable immediately. Thus, as in CTS, upon discovery of failure to meet an LCO appropriate action are taken. This change is designated as administrative because the technical requirements of the specifications have not changed.

Turkey Point Unit 3 and Unit 4 Page 2 of 7

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR MORE RESTRICTIVE CHANGES M01 CTS 3.8.1.1.b.1)d provides lube oil storage requirements for the Unit 3 EDGs and CTS 4.8.1.1.2.a.3 provides an SR to verify the lubricating oil inventory in storage for Unit 3 EDGs. The CTS does not provide EDG total lube oil inventory requirements for the Unit 3 EDGs and Unit 4 EDGs, or the lube oil contained in the EDG lube oil sump. ITS LCO 3.8.3, in part, requires the lube oil inventory to be within limits for each required EDG that includes the lube oil in the EDG lube oil sump. The Applicability for this requirement is when the associated EDG is required to be OPERABLE. ITS SR 3.8.3.2 requires a verification that the lube oil inventory is greater than a 7-day supply for each EDG, including the lube oil in storage and the lube oil in the EDG sump. ITS 3.8.3, ACTION B and ACTION F, provide Actions if the limit of ITS SR 3.8.3.2 is not met. ITS 3.8.3, ACTION F, provides similar requirements as are in CTS, declaring the EDG inoperable immediately if not within limits. ITS 3.8.3, ACTION B, provides a Required Action to restore the lube oil inventory to greater than or equal to the 7-day supply if there is greater than or equal to a 6-day supply. This changes the CTS by adding a lube oil inventory requirement for the EDGs that includes both the inventory in the EDG's sump and the inventory in storage along with an appropriate ACTION and SR.

The purpose of the lube oil inventory requirement in ITS LCO 3.8.3 and SR 3.8.3.2 is to ensure a 7-day lube oil inventory for each EDG is on site. The proposed ITS SR 3.8.3.2 will ensure the 7-day inventory requirement is met. In addition, ITS 3.8.3, ACTION B, will allow the 7-day limit to not be met for each EDG for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, provided sufficient lube oil inventory is available for 6 days. If the lube oil inventory is not restored within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or if the 6-day limit is not met, then ACTION F requires the associated EDG to be declared inoperable immediately. Furthermore, as stated in the ITS 3.8.3 ACTIONS Note, ITS 3.8.3, ACTION B, can be separately entered for each EDG. This change is acceptable because a period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to complete restoration of the required volume prior to declaring the EDG inoperable is reasonable based on the remaining capacity (> 6 days) and the low rate of usage. In addition, the total required inventory must be verified, not only the inventory in storage. This change is considered more restrictive because it adds a new requirement to maintain a 7-day lube oil inventory for Unit 4 EDGs and requires the verification of the total inventory of lube oil for Unit 3 EDGs.

M02 The CTS does not provide any starting air receiver pressure requirements. ITS LCO 3.8.3, in part, requires the required starting air receiver pressure to be within limits for each required EDG. The Applicability for this requirement is when the associated EDG is required to be OPERABLE. ITS SR 3.8.3.4 requires verification that the required starting air receiver pressure is the 5 start air pressure for each EDG. ITS 3.8.3 ACTION E provides an ACTION if the limit of ITS SR 3.8.3.4 is not met. This changes the CTS by adding a starting air receiver pressure requirement, with an appropriate ACTION and SR.

The purpose of the starting air receiver pressure requirement in ITS LCO 3.8.3 and SR 3.8.3.4 is to ensure sufficient starting air for five successive air start attempts for each EDG without recharging the air start receivers. The proposed Turkey Point Unit 3 and Unit 4 Page 3 of 7

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR ITS SR 3.8.3.4 value, is the 5 start air pressure will ensure the five-diesel air start requirement is met. The EDG air start system design includes four air start receivers and four air start motors arranged in two sets. Each set includes two air start receivers and two air start motors. Each EDG can be aligned such that one or two sets of air starting sets can be aligned to start the EDG. With two sets of air start receivers/motors aligned to the EDG, 195 psig (Unit 3 EDGs) or 185 psig (Unit 4 EDGs) receiver air pressure is required for 5 successive air start attempts. With one set of air start receivers/motors aligned to the EDG, 212 psig (Unit 3 EDGs) or 195 psig (Unit 4 EDGs) receiver air pressure is required for 5 successive air start attempts. In addition, ITS 3.8.3 ACTION E will allow the five-diesel air start requirement to not be met for each EDG for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, provided the required starting air receiver pressure is sufficient for one EDG start ( 160 psig).

If the required starting air receiver pressure is not restored within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or if the required starting air receiver pressure is not sufficient for one start, then the associated EDG is required to be declared inoperable immediately. Furthermore, as stated in the ITS 3.8.3 ACTIONS Note, ITS 3.8.3 ACTION E can be separately entered for each EDG. Therefore, this change is acceptable because it provides additional assurance that the EDGs will be capable of performing their function. This change is considered more restrictive because it adds a new requirement to maintain a starting air receiver pressure for each EDG.

M03 CTS LCO 3.8.1.1.b.1)b) requires, in part, a common Fuel Storage System containing a minimum volume of 38,000 gallons of fuel.** Footnote ** modifies this requirement stating, in part, that a temporary Class III fuel storage system containing a minimum volume of 38, 000 gallons of fuel oil may be used for up to 10 days during the performance of Surveillance Requirement 4.8.1.1.2i.1 [fuel oil storge tank cleaning] for the Unit 3 storage tank while Unit 3 is in Modes 5, 6, or defueled. If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively. ITS LCO 3.8.3 Note states that the Unit 3 fuel oil storage subsystem may be considered within limits for 10 days when a temporary Class III fuel oil storage subsystem containing greater than or equal to a 7 day supply of fuel oil is used during Unit 3 fuel oil storage tank cleaning while Unit 3 is in MODE 5, 6, or defueled. This changes the CTS by removing the direction to specific Required Actions if the temporary subsystem is used longer than 10 days.

The purpose of CTS LCO 3.8.1.1.b.1)b) Footnote ** is to provide an allowance for removing the accumulated sediment and cleaning the Unit 3 EDG fuel oil storage tank. The two Unit 3 EDGs share a common fuel oil storage tank (FOST) that has a 64,000 gallon capacity. The FOST is required to maintain a minimum of 38,000 gallons to permit one EDG to operate at its 168-hour rating of 2950 kW for at least 7 days. Two fuel oil transfer pumps (one per line) are provided to transfer fuel oil from the FOST to the day tank of each EDG. The footnote allows the use of a temporary system for storage and delivery of at least a 7-day supply of fuel oil for one Unit 3 EDG operation. This temporary system is required only for a period of 10 days. CTS 3.8.1, Applicable in MODES 1, 2, 3, and 4, provides two Actions for an inoperable EDG, CTS 3.8.1 Action b and Turkey Point Unit 3 and Unit 4 Page 4 of 7

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Action d. ITS does not include the exception from applying the ITS equivalent of CTS 3.8.1 Action d, as modified. The change is acceptable because an exception to performing a Required Action for an inoperable EDG is removed and the Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. The change is designated as more restrictive because it removes an allowance to not perform Required Actions.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.1.b.1)b, CTS 3.8.1.1.b.2)b, and CTS 3.8.1.2.b.2 require a separate fuel storage system containing a minimum volume of 38,000 gallons of fuel for Unit 3 and 34,700 gallons of fuel for Unit 4.

CTS 3.8.1.1.b.1)d requires lubricating oil storage containing a minimum volume of 120 gallons of lubricating oil for Unit 3 EDGs. ITS SR 3.8.3.1 and SR 3.8.3.2 require verifying that each fuel oil storage tank contains a 7-day supply of fuel oil and the lubricating oil inventory is a 7-day supply when the associated EDG is required to be OPERABLE. This changes the CTS by moving the specific values for the fuel oil and lube oil inventory to the Technical Specification Bases.

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS 3.8.1.1.b.1)b, CTS 3.8.1.1.b.2)b, CTS 3.8.1.2.b.2, and CTS 3.8.1.1.b.1)d is to ensure that the EDGs have sufficient fuel oil and lube oil to perform the associated specified safety function when the EDGs are required to be OPERABLE. ITS SR 3.8.3.1 and SR 3.8.3.2 will continue to ensure that sufficient fuel is contained in the fuel oil storage tank and a sufficient volume of lube oil is available for the EDGs to perform the associated specified safety function when the EDGs are required to be OPERABLE. In addition, this change is acceptable because these types of details will be adequately controlled in the Technical Specification Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. The program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as less restrictive removal of detail change because details are being moved from the Technical Specifications to the ITS Bases LA02 (Type 1 - Removing Details of System Design and System Description, Including R2 Design Limits) CTS 3.8.1.1.b.1)e requires that the Operability of a Unit 3 EDG includes the capability to transfer lubricating oil from storage to the EDG unit.

ITS SR 3.8.3.2 requires verifying lubricating oil inventory is a 7-day supply.

This changes the CTS by removal of an explicit LCO requirement for Unit 3 EDGs.

Turkey Point Unit 3 and Unit 4 Page 5 of 7

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR The removal of the confirmation of the capability to transfer lubricating oil from storage to the EDG unit from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement to verify the lubricating oil inventory is a 7-day supply. Inherent in the 7-day requirement is the capability to transfer lubricating oil from storage to the EDG unit. If a supply of lube oil cannot be transferred to the Unit 3 EDG, it cannot be included in the 7-day supply. Also, this change is acceptable because these types of procedural details will be adequately controlled in the Technical Specification Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.

This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because the verification of the capability to transfer lubricating oil from storage to the EDG unit is being removed from the Technical Specifications.

LA03 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance R2 Frequency Control Program) CTS 4.8.1.1.2.i requires that, in accordance with the Surveillance Frequency Control Program, to drain each fuel oil storage tank, remove the accumulated sediment, and clean the tank. CTS 4.8.1.1.2.j requires at least once per 10 years, for Unit 4 only, to perform a pressure test of those portions of the diesel fuel oil system designed to Section III, subsection ND of the ASME Code in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda. ITS 3.8.3 does not include these requirements for the fuel oil storage tanks. This changes the CTS by moving these fuel oil storage tank requirements from the Technical Specifications to the Technical Requirements Manual (TRM).

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS 4.8.1.1.2.i is to ensure the cleanliness of the tanks. The purpose of CTS 4.8.1.1.2.j is to ensure the leak tightness of the tank. The criteria and Frequencies established in the ITS 5.5.10, "Diesel Fuel Oil Testing Program," and ITS SR 3.8.3.3 will ensure the diesel fuel oil is at a quality that will ensure proper operation of the EDG during a design basis accident (DBA). Also, this change is acceptable because the removed information will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated.

This change is designated as a less restrictive removal of detail change because information is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.1.1 and CTS 3.8.1.2 do not provide compensatory actions if the volume of fuel oil in a storage tank is less than the specified limit. Thus, if the minimum required volume is not met, the associated EDG must be declared inoperable and the actions of CTS 3.8.1.1 or CTS 3.8.1.2 must be entered, as appropriate. ITS 3.8.3, ACTION A, allows a Turkey Point Unit 3 and Unit 4 Page 6 of 7

DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR delay in declaring the associated EDG inoperable as long as the volume of stored fuel oil is greater than a six-day supply. ITS 3.8.3, Required Action A.1, allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the fuel oil volume to within limits. As stated in the ACTIONS Note, a separate entry into the ACTION is allowed for each EDG. If the Required Action and associated Completion Time are not met or if the fuel oil storage tank volume is less than a 6-day supply, the associated EDG must be declared inoperable immediately, as required by ITS 3.8.3, ACTION F. This changes the CTS by allowing the EDGs to not be declared inoperable with the fuel oil 7-day storage tank volume not within the specified Surveillance limit as long as the associated EDG has a 6-day supply of fuel oil in the storage tank.

The purpose of ITS 3.8.3, ACTION A, is to allow time to restore the stored diesel fuel oil volume to within the specified limit for a given EDG. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to a degraded condition in order to minimize risk associated with continued operation while providing time to restore inventory. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features including the capacity and capability of remaining systems or features, reasonable time for repairs or replacement, and the low probability of a design basis accident (DBA) occurring during the repair period. The addition of ITS 3.8.3, ACTION A, will allow each EDG to not be declared inoperable with the associated stored diesel fuel oil volume not within the specified Surveillance limit if the EDG has enough fuel oil for 6 days of operation. In this Condition, the 7-day fuel oil supply for the EDG is not available. However, the Condition is restricted to fuel oil volume reductions that maintain at least a 6-day supply.

These circumstances may be caused by events such as full load operation required after an inadvertent start while at minimum required fuel oil level, or feed and bleed operations, which may be necessary due to increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required volume prior to declaring the associated EDG inoperable. This period is acceptable based on the remaining capacity (> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Turkey Point Unit 3 and Unit 4 Page 7 of 7

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air DOC A02 LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG). 1 emergency EDG INSERT 1 EDG DOC A02 APPLICABILITY: When associated DG is required to be OPERABLE. 1 ACTIONS

NOTE-----------------------------------------------------------

EDG DOC L01 Separate Condition entry is allowed for each DG. 1 CONDITION REQUIRED ACTION COMPLETION TIME EDG DOC L01 A. One or more DGs with A.1 Restore fuel oil level to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 1 fuel level less than a within limits.

[7] day supply and 2 greater than a [6] day supply in storage tank.

EDG DOC M01 B. One or more DGs with B.1 Restore lube oil inventory to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 1 lube oil inventory less within limits.

than a [7] day supply 2 and greater than a

[6] day supply. 2 EDG 3.8.1.1 C. One or more DGs with C.1 Restore fuel oil total 7 days 1 ACTION h stored fuel oil total particulates to within limits.

particulates not within limit.

EDG 3.8.1.1 D. One or more DGs with D.1 Restore stored fuel oil 30 days 1 ACTION g new fuel oil properties properties to within limits.

not within limits.

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.3-1 Rev. 5.0 1

CTS 1

INSERT 1 3.8.1.1.b.1)b) ------------------------------------------------------------NOTE-----------------------------------------------------------

Footnote **,

3.8.1.2.b.2)

The Unit 3 fuel oil storage subsystem may be considered within limits for 10 days when a Footnote **, temporary Class III fuel oil storage subsystem containing greater than or equal to a 7 day supply 4.8.1.1.2.1 of fuel oil is used during Unit 3 fuel oil storage tank cleaning while Unit 3 is in MODE 5, 6, or Footnote*

defueled.

Insert Page 3.8.3-1

CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME EDG DOC M02 E. One or more DGs with E.1 Restore starting air receiver 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 1 starting air receiver pressure to [225] psig.

required pressure < [225] psig 5 start air pressure 2 and [125] psig.

160 EDG 3.8.1.1.b.1)b) F. Required Action and F.1 Declare associated DG Immediately 1 Footnote **, associated Completion inoperable.

4.8.1.1.2.i Footnote *, Time not met.

3.8.1.2 Action Footnote **

OR EDG One or more DGs with 1 diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3.8.1.1.b.1)b),

3.8.1.1.b.2)b), SR 3.8.3.1 Verify each fuel oil storage tank contains a [7] day [ 31 days 4.8.1.1.2.a.2) supply of fuel. 2 3.8.1.2.b.2)

OR In accordance with the Surveillance Frequency Control Program ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.3-2 Rev. 5.0 1

CTS Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 3.8.1.1b.1)d),

3.8.1.1b.2)b),

4.8.1.1.2a.3), SR 3.8.3.2 Verify lubricating oil inventory is a [7] day supply. [ 31 days 3.8.1.2b.4),

2 3.8.1.2b.5)

OR In accordance with the Surveillance Frequency Control Program ] 2 4.8.1.1.2e, SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance 4.8.1.1.2f are tested in accordance with, and maintained within with the Diesel the limits of, the Diesel Fuel Oil Testing Program. Fuel Oil Testing Program EDG DOC M02 SR 3.8.3.4 Verify each DG air start receiver pressure is [ 31 days 1 2

[225] psig.

OR 5 start air pressure In accordance with the Surveillance Frequency Control Program ] 2 4.8.1.1.2d SR 3.8.3.5 Check for and remove accumulated water from each [ [31] days fuel oil storage tank. 2 OR In accordance with the Surveillance Frequency Control Program ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.3-3 Rev. 5.0 1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air BASES emergency EDG BACKGROUND Each diesel generator (DG) is provided with a storage tank having a fuel 1 oil capacity sufficient to operate that diesel for a period of [7] days while 2 EDG the DG is supplying maximum post loss of coolant accident load demand 1 8.2 discussed in the FSAR, Section [9.5.4.2] (Ref. 1) [and Regulatory 1 U 2 Guide 1.137 (Ref. 2)]. The maximum load demand is calculated using the EDG assumption that a minimum of any two DGs is available. This onsite fuel 1 oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources.

one Fuel oil is transferred from storage tank to day tank by either of two 1 EDG transfer pumps associated with each storage tank. Redundancy of pumps and piping precludes the failure of one pump, or the rupture of any EDG pipe, valve or tank to result in the loss of more than one DG. All outside 1 tanks, pumps, and piping are located underground.

EDG For proper operation of the standby DGs, it is necessary to ensure the 1 proper quality of the fuel oil. Regulatory Guide 1.137 (Ref. 2) addresses the recommended fuel oil practices as supplemented by ANSI N195 (Ref. 3). The fuel oil properties governed by these SRs are the water and sediment content, the kinematic viscosity, specific gravity (or API gravity),

and impurity level.

The DG lubrication system is designed to provide sufficient lubrication to EDG 1 permit proper operation of its associated DG under all loading conditions.

The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during Unit 4 operation. Each engine oil sump contains an inventory capable of 1 supporting a minimum of [7] days of operation. [The onsite storage in Unit 3 2 addition to the engine oil sump is sufficient to ensure [7] days of 1 continuous operation.] This supply is sufficient to allow the operator to replenish lube oil from outside sources.

EDG Each DG has an air start system with adequate capacity for five 1

successive start attempts on the DG without recharging the air start receiver(s).

Each EDG has four air motors, two independent 100% capacity sets consisting of an upper and lower air motor with two sets of two air receivers. Air receiver tanks A

& B provide an air supply to one set of air start motors and air receiver tanks C & D provide an air supply to the second set of air start motors.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.3-1 Rev. 5.0 1

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient U

SAFETY 14 analyses in the FSAR, Chapter [6] (Ref. 4), and in the FSAR, 1 2

ANALYSES Chapter [15] (Ref. 5), assume Engineered Safety Feature (ESF) systems EDG are OPERABLE. The DGs are designed to provide sufficient capacity, 1 capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

Since diesel fuel oil, lube oil, and the air start subsystem support the operation of the standby AC power sources, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Stored diesel fuel oil is required to have sufficient supply for [7] days of 2 full load operation. It is also required to meet specific standards for quality. Additionally, sufficient lubricating oil supply must be available to ensure the capability to operate at full load for [7] days. This requirement, 2 in conjunction with an ability to obtain replacement supplies within EDG

[7] days, supports the availability of DGs required to shut down the 2 1 reactor and to maintain it in a safe condition for an anticipated operational EDG occurrence (AOO) or a postulated DBA with loss of offsite power. DG 1 day tank fuel requirements, as well as transfer capability from the storage tank to the day tank, are addressed in LCO 3.8.1, "AC Sources -

Operating," and LCO 3.8.2, "AC Sources - Shutdown."

The starting air system is required to have a minimum capacity for five EDG INSERT 1 successive DG start attempts without recharging the air start receivers. 1 APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensure the availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an AOO or a postulated DBA. Since stored diesel fuel oil, lube oil, and the starting air subsystem support LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil, lube oil, and starting air EDG are required to be within limits when the associated DG is required to be 1 OPERABLE.

ACTIONS The ACTIONS Table is modified by a Note indicating that separate EDG Condition entry is allowed for each DG. This is acceptable, since the 1 Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required EDG Actions for one inoperable DG subsystem may allow for continued 1 EDG operation, and subsequent inoperable DG subsystem(s) are governed by separate Condition entry and application of associated Required Actions.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.3-2 Rev. 5.0 1

ITS 3.8.3 1

INSERT 1 Each EDG's air start system contains two sets of two air receivers. The air receivers are sized to ensure that the system has sufficient capacity, with a pressure of 195/185 psig (Unit 3/Unit 4) in all four air receivers and four air start motors available or 212/195 psig (Unit 3/Unit 4) with only two air receivers and two air start motors available, for four unsuccessful attempts and one successful EDG starting attempt without the need for recharging. These values are for the receivers sizing criteria and are not the minimum pressure required to start the EDG. If either set of air receivers is out of service, the other set of air receivers with either set of air start motors or both sets of air start motors is capable of starting the associated EDG. Redundant air start subsystems are not required for operability of the EDG.

This LCO is modified by a Note that allows the use of a temporary Class III fuel oil storage and transfer system to maintain OPERABILITY of Unit 3 EDGs during performance of Unit 3 fuel oil storage tank cleaning. Use of this temporary system provides for storage and delivery of at least a 7-day supply of fuel oil for one Unit 3 EDG operation. This temporary system is allowed only for a period of 10 days; if 10 days are exceeded using the temporary fuel oil storage system appropriate Conditions and Required Actions are entered.

Insert Page B 3.8.3-2

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued)

A.1 EDG In this Condition, the [7] day fuel oil supply for a DG is not available. 2 1 32,600 gallons However, the Condition is restricted to fuel oil level reductions that for Unit 3 and maintain at least a [6] day supply. The fuel oil level equivalent to a [6] day 1 2

30,000 gallons supply is [28,285] gallons. These circumstances may be caused by for Unit 4 events, such as full load operation required after an inadvertent start while at minimum required level, or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required level prior to declaring EDG the DG inoperable. This period is acceptable based on the remaining 1 capacity (> [6] days), the fact that procedures will be initiated to obtain 2 replenishment, and the low probability of an event during this brief period.

B.1 In this Condition, the [7] day lube oil inventory i.e., sufficient lubricating oil EDG 2 1 to support [7] days of continuous DG operation at full load conditions is not available. However, the Condition is restricted to lube oil volume 170 gallons for reductions that maintain at least a [6] day supply. The lube oil inventory Unit 3 and 160 2 gallons for Unit 4 equivalent to a [6] day supply is [425] gallons. This restriction allows sufficient time to obtain the requisite replacement volume. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required EDG volume prior to declaring the DG inoperable. This period is acceptable 1 based on the remaining capacity (> [6] days), the low rate of usage, the 2 fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

C.1 This Condition is entered as a result of a failure to meet the acceptance criterion of SR 3.8.3.5. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poor sample procedures (bottom sampling),

contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, and particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.3-3 Rev. 5.0 1

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS (continued) performance has been recently demonstrated (within 31 days), it is EDG prudent to allow a brief period prior to declaring the associated DG 1 inoperable. The 7 day Completion Time allows for further evaluation, EDG resampling and re-analysis of the DG fuel oil. 1 D.1 With the new fuel oil properties defined in the Bases for SR 3.8.3.4 not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil, when mixed with previously stored fuel oil, remains acceptable, or to restore the stored fuel oil properties. This restoration may involve feed and bleed procedures, EDG filtering, or combinations of these procedures. Even if a DG start and 1 load was required during this time interval and the fuel oil properties were EDG outside limits, there is a high likelihood that the DG would still be capable 1 of performing its intended function.

< 212 psig (1 air start set available) or < 195 psig (2 air start E.1 sets available) for Unit 3 and < 195 psig (1 air start set available) or < 185 psig (2 air start sets available) for Unit 4 With starting air receiver pressure < [225] psig, sufficient capacity for five 2 EDG successive DG start attempts does not exist. However, as long as the 1 160 receiver pressure is > [125] psig, there is adequate capacity for at least 2 EDG one start attempt, and the DG can be considered OPERABLE while the 1 air receiver pressure is restored to the required limit. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration to the required pressure prior to declaring the DG inoperable. This period is acceptable based on EDG 1 the remaining air start capacity, the fact that most DG starts are accomplished on the first attempt, and the low probability of an event during this brief period. 1 An EDG air start set consists of 2 air receivers and 2 air motors.

F.1 With a Required Action and associated Completion Time not met, or one EDG or more DG's fuel oil, lube oil, or starting air subsystem not within limits 1 for reasons other than addressed by Conditions A through D, the EDG associated DG may be incapable of performing its intended function and 1 must be immediately declared inoperable.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.3-4 Rev. 5.0 1

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil EDG in the storage tanks to support each DG's operation for [7] days at full 1 38,000 gallons for 2 Unit 3 and 34,700 load. The fuel oil level equivalent to a [7] day supply is [33,000] gallons gallons for Unit 4 when calculated in accordance with References 2 and 3. The required fuel storage volume is determined using the most limiting energy content of the stored fuel. Using the known correlation of diesel fuel oil absolute specific gravity or API gravity to energy content, the required diesel generator output, the corresponding fuel consumption rate, the onsite fuel storage volume required for [7] days of operation can be determined. 2 SR 3.8.3.3 requires a new fuel to be tested to verify that the absolute specific gravity or API gravity is within the range assumed in the diesel fuel oil consumption calculations. The [7] day period is sufficient time to 2 place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location.

[ The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period. 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 3 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.8.3.2 This Surveillance ensures that sufficient lube oil inventory is available to 197 gallons for EDG Unit 3 and 185 support at least [7] days of full load operation for each DG. The lube oil 2 1 gallons for Unit 4 inventory equivalent to a [7] day supply is [500] gallons and is based on 2 EDG the DG manufacturer consumption values for the run time of the DG. 1 Implicit in this SR is the requirement to verify the capability to transfer the EDG lube oil from its storage location to the DG, when the DG lube oil sump 1 does not hold adequate inventory for [7] days of full load operation 2 without the level reaching the manufacturer recommended minimum level.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.3-5 Rev. 5.0 1

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

[ A 31 day Frequency is adequate to ensure that a sufficient lube oil supply is onsite, since DG starts and run time are closely monitored by the unit staff. 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 3 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.8.3.3 The tests listed below are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for contaminating the entire volume of fuel oil in the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank(s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows:

81

a. Sample the new fuel oil in accordance with ASTM D4057-[ ] 2 (Ref. 6),

81

b. Verify in accordance with the tests specified in ASTM D975-[ ] 2 (Ref. 6) that the sample has an absolute specific gravity at 60/60°F of 0.83 and 0.89 or an API gravity at 60°F of 27° and 39° when 80 tested in accordance with ASTM D1298-[ ] (Ref. 6), a kinematic 2 viscosity at 40°C of 1.9 centistokes and 4.1 centistokes, and a flash point of 125°F, and
c. Verify that the new fuel oil has a clear and bright appearance with 82 proper color when tested in accordance with ASTM D4176-[ ] or a 2 water and sediment content within limits when tested in accordance D1796 with [ASTM D2709-[ )) (Ref. 6). 2 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.3-6 Rev. 5.0 1

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks.

Within 31 days following the initial new fuel oil sample, the fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-[ ] (Ref. 7) are met for new fuel oil when tested in 81 accordance with ASTM D975-[ ] (Ref. 6), except that the analysis for 2 79 sulfur may be performed in accordance with ASTM D1552-[ ], or 82 ASTM D2622-[ ], or ASTM D4294-[ ] (Ref. 6). The 31 day period is acceptable because the fuel oil properties of interest, even if they were EDG 1 not within stated limits, would not have an immediate effect on DG operation. This Surveillance ensures the availability of high quality fuel oil EDG for the DGs. 1 Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.

or D2276 Particulate concentrations should be determined in accordance with ASTM D5452-[ ] (Ref. 6). This method involves a gravimetric 2 determination of total particulate concentration in the fuel oil and has a limit of 10 mg/l. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing. [For those designs in which the 2 total stored fuel oil volume is contained in two or more interconnected tanks, each tank must be considered and tested separately.] 2 The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.

SR 3.8.3.4 This Surveillance ensures that, without the aid of the refill compressor, EDG sufficient air start capacity for each DG is available. The system design 1 requirements provide for a minimum of [five] engine start cycles without EDG 2 recharging. [A start cycle is defined by the DG vendor, but usually is 1 measured in terms of time (seconds of cranking) or engine cranking speed.] The pressure specified in this SR is intended to reflect the lowest 2 1 value at which the [five] starts can be accomplished.

A pressure 212 psig (1 air start set available) or 195 psig (2 air start sets available) for Unit 3 and 195 psig (1 air start set available) or 185 psig (2 air start sets available) for Unit 4 reflect pressures Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.3-7 Rev. 5.0 1

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The 31 day Frequency takes into account the capacity, capability, redundancy, and diversity of the AC sources and other indications available in the control room, including alarms, to alert the operator to 2 below normal air start pressure.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 3 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.8.3.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel storage tanks eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the EDG fuel oil during DG operation. Water may come from any of several 1 sources, including condensation, ground water, rain water, and contaminated fuel oil, and from breakdown of the fuel oil by bacteria.

Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. [ The Surveillance Frequency of 31 days is established by Regulatory Guide 1.137 (Ref. 2). This SR is for preventive maintenance.

The presence of water does not necessarily represent failure of this SR, provided the accumulated water is removed during performance of the 2 Surveillance.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.3-8 Rev. 5.0 1

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 3 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

U

8.2 REFERENCES

1. FSAR, Section [9.5.4.2]. 1 2
2. Regulatory Guide 1.137.
3. ANSI N195, 1976.

U

4. FSAR, Chapter [6]. 1 2 U 14
5. FSAR, Chapter [15]. 1 2 81 81 80 82
6. ASTM Standards: D4057-[ ]; D975-[ ]; D1298-[ ]; D4176-[ ]; 2

[D2709-[ ];] D1552-[ ]; D2622-[ ]; D4294-[ ]; D5452-[ ].

D1796 79 82 81 D2276-78

7. ASTM Standards, D975-[ ], Table 1. 2 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.3-9 Rev. 5.0 1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.3 BASES, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR There are no specific No Significant Hazards Considerations for this Specification.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

ATTACHMENT 4 ITS 3.8.4, DC SOURCES - OPERATING

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS A01 ITS 3.8.4 R2 3/4.8.2 D.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION Add proposed LCO 3.8.4 A02 LCO 3.8.4 3.8.2.1 The following D.C. electrical sources shall be OPERABLE:*#

LA01

a. 125-volt D.C. Battery Bank 3A or spare battery bank D-52 and associated full capacity charger(s)
1) 3A1 powered by motor control center (MCC) 3C with EDG 3A OPERABLE, or
2) 3A2 powered by MCC 4D with EDG 4A and 4B OPERABLE, or L01
3) 3A1 powered by MCC 3C with EDG 3A OPERABLE and 3A2 powered by MCC 4D with EDG 4A and 4B OPERABLE, LA01
b. 125-volt D.C. Battery Bank 3B or spare battery bank D-52 and associated full capacity charger(s)
1) 3B1 powered by MCC 3B with EDG 3B OPERABLE, or
2) 3B2 powered by MCC 4D with EDG 4A and 4B OPERABLE, or L01
3) 3B1 powered by MCC 3B with EDG 3B OPERABLE and 3B2 powered by MCC 4D with EDG 4A and 4B OPERABLE, LA01
c. 125-volt D.C. Battery Bank 4A or spare battery bank D-52 and associated full capacity charger(s)
1) 4A1 powered by MCC 4C with EDG 4A OPERABLE, or
2) 4A2 powered by MCC 3D with EDG 3A and 3B OPERABLE, or L01
3) 4A1 powered by MCC 4C with EDG 4A OPERABLE and 4A2 powered by MCC 3D with EDG 3A and 3B OPERABLE, LA01
d. 125-volt D.C. Battery Bank 4B or spare battery bank D-52 and associated full capacity charger(s)
1) 4B1 powered by MCC 4B with EDG 4B OPERABLE, or
2) 4B2 powered by MCC 3D with EDG 3A and 3B OPERABLE, or L01
3) 4B1 powered by MCC 4B with EDG 4B OPERABLE and 4B2 powered by MCC 3D with EDG 3A and 3B OPERABLE.

Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION: L01

a. With one or more of the required battery chargers OPERABLE but not capable of being powered from its associated OPERABLE diesel generator(s), restore the capability within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units simultaneously.
  • All battery chargers required to satisfy the LCO shall be powered from separate MCCs.

LA02

  1. Inoperability of the required EDGs specified in the LCO requirements below does not constitute inoperability of the associated battery chargers or battery banks.

TURKEY POINT - UNITS 3 & 4 3/4 8-13 AMENDMENT NOS. 284 AND 278 Page 1 of 3

ITS A01 ITS 3.8.4 R2 D.C. SOURCES LIMITING CONDITION FOR OPERATION A03 ACTION: (Continued) unit DC electrical power trains 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for Required Action A.3 L02 ACTION A, b. With one of the required battery banks inoperable, or with none of the full-capacity chargers ACTION B, ACTION C associated with a battery bank OPERABLE, restore all battery banks to OPERABLE status and at least one charger associated with each battery bank to OPERABLE status within two hours* or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY A04 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION ACTION D applies to both units simultaneously. MODE 4 18 L03 SURVEILLANCE REQUIREMENTS Add proposed Required Action A.1 and A.2 L02 4.8.2.1 Each 125-volt battery bank and its associated full capacity charger(s) shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying that:
1) The parameters in Table 4.8-2 meet the Category A limits, and See ITS 3.8.6 SR 3.8.4.1 2) The total battery terminal voltage is greater than or equal to 129 volts on float charge and the battery charger(s) output voltage is 129 volts, and minimum established float voltage LA03
3) If two battery chargers are connected to the battery bank, verify each battery charger is supplying a minimum of 10 amperes, or demonstrate that the battery charger supplying less than 10 amperes will accept and supply the D.C. bus load independent of its associated battery charger. LA04
b. In accordance with the Surveillance Frequency Control Program and within 7 days after a battery discharge with battery terminal voltage below 105 volts (108.6 volts for spare battery D-52), or battery overcharge with battery terminal voltage above 143 volts, by verifying that:
1) The parameters in Table 4.8-2 meet the Category B limits, See ITS 3.8.6
2) The average electrolyte temperature of every sixth cell is above 60°F, and
3) There is no visible corrosion at either terminals or connectors, or verify battery connection resistance is:

See ITS 5.5.14 R2 Battery Connection Limit (Micro-Ohms) 3B, 4A inter-cell / termination < 29 inter-cell (brace locations) < 30 transition cables < 125 or total battery connections < 1958 Battery Connection Limit (Micro-Ohms) 3A, 4B, D-52 inter-cell / termination < 35 inter-cell (brace locations) < 40 transition cables < 125 or total battery connections < 2463

c. In accordance with the Surveillance Frequency Control Program by verifying that:
1) The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration, L01 ACTION B *Can be extended to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the opposite unit is in MODE 5, 6, or defueled and each of the remaining required battery chargers is capable of being powered from its associated diesel generator(s).

TURKEY POINT - UNITS 3 & 4 3/4 8-14 AMENDMENT NOS. 289 AND 283 Page 2 of 3

ITS A01 ITS 3.8.4 R2 D.C. SOURCES SURVEILLANCE REOUIREMENTS (Continued) See ITS 5.5.14 R2

2) The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material, SR 3.8.4.2 3) Each 400 amp battery charger (associated with Battery Banks 3A and 4B) will supply at least 400 amperes at 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and each 300 amp battery charger (associated with Battery Banks 3B and 4A) will supply at least 300 amperes at 129 LA05 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and the minimum established float voltage Add proposed second option for SR 3.8.4.2
4) Battery Connection resistance is: L04 Battery Connection Limit (Micro-Ohms) 3B, 4A inter-cell / termination < 29 inter-cell (brace locations) < 30 transition cables < 125 or See ITS total battery connections < 1958 5.5.14 R2 Battery Connection Limit (Micro-Ohms) 3A, 4B, D-52 inter-cell / termination < 35 inter-cell (brace locations) < 40 transition cables < 125 or total battery connections < 2463 Add proposed SR 3.8.4.3 Note 2 A05 SR 3.8.4.3 d. In accordance with the Surveillance Frequency Control Program, during shutdown**, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.
e. At least once per 12 months, during shutdown**, by giving performance discharge tests of battery capacity to any battery that shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% [7% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of rated capacity from its average on previous performance tests, or is below 90% [93% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturers rating. See ITS 3.8.6
f. In accordance with the Surveillance Frequency Control Program, during shutdown**, by verifying that the battery capacity is at least 80% [87% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturers rating when subjected to a performance discharge test.

SR 3.8.4.3 Once per 60-month interval this performance discharge test may be performed in lieu of the Note 1 battery service test required by Specification 4.8.2.1.d.

The modified L05 A05 SR 3.8.4.3 **Except that the spare battery bank D-52, and any other battery out of service when spare battery bank D-52 is Note 2 in service may be tested with simulated loads during operation.

TURKEY POINT - UNITS 3 & 4 3/4 8-15 AMENDMENT NOS. 263 AND 258 Page 3 of 3

DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.2.1 requires, in part, a 125-volt DC battery bank and a full capacity charger for each of four direct current (DC) electrical sources. ITS Limiting Condition for Operation (LCO) 3.8.4 requires that four trains of the DC electrical power subsystem shall be OPERABLE. This changes the CTS by changing the statement that the following DC electrical sources shall be OPERABLE, then listing the required sources and combining the requirements for the battery, battery charger, and battery charger power supply into one separate Specification stating four trains of the DC electrical power subsystem shall be OPERABLE.

The purpose, in part, of CTS 3.8.2.1 is to define LCO for required DC systems during plant operation. The change is acceptable because ITS LCO 3.8.4 retains the requirements of CTS 3.8.2.1 associated with required DC sources. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 3.8.2.1, ACTION b, states, in part, that with one of the required battery banks inoperable, or with none of the full-capacity chargers associated with a battery bank OPERABLE, restore all battery banks to OPERABLE status and at least one charger associated with each battery bank to OPERABLE status.

ITS 3.8.4, ACTION B and ACTION C, state, in part, that with one DC electrical power train inoperable to restore the DC electrical power train to OPERABLE status. This changes the CTS by describing the Condition and Required Action as a train (battery bank and associated charger) instead of listing the train components separately.

The purpose of CTS 3.8.2.1, ACTION b, is to prescribe remedial measures required under designated conditions. Whether the condition lists the R2 components (battery bank or associated battery chargers) or lists the combination of the components as a train only changes the manner that the condition is presented. CTS 3.8.2.1, Action b, is applied as an inclusive condition when any combination of required battery or chargers are inoperable (i.e., one required battery bank inoperable, or associated full capacity chargers inoperable, or both the required battery bank and associated full capacity chargers R2 inoperable). This application is also consistent with CTS 3.8.3.1, Action d, which requires in part, reenergizing the DC bus from its associated battery bank within two hours or in accordance with the Risk Informed Completion Time Program Turkey Point Unit 3 and Unit 4 Page 1 of 9

DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING with one DC bus not energized from its associated battery bank or associated charger. As such, ITS 3.8.4, ACTIONS B and C are technically equivalent to the CTS requirements, consistent with both CTS 3.8.2.1, Action b, and CTS 3.8.3.1, R2 Action d. Presenting ITS 3.8.4 Conditions B and C on train basis instead of a component basis clarifies the intended application of the requirement. This change is acceptable because no technical changes are made. This change is designated as administrative because it does not result in technical changes to the CTS.

A04 CTS 3.8.2.1, Action b, includes a statement that the action applies to both units simultaneously. ITS 3.8.4, does not explicitly state that the ACTIONS apply to both units since the statement is redundant to the requirements of CTS 3.0.5.a (ITS LCO 3.0.10.a). This changes the CTS by deleting redundant detail.

The purpose of the CTS statement is to ensure action requirements are performed simultaneously for both units when required equipment shared between the units is inoperable. This statement is redundant to the generic requirement provided in CTS 3.0.5.a (ITS LCO 3.0.10.a) and therefore is not necessary. ITS LCO 3.0.10.a states, "Whenever the LCO refers to systems or components which are shared by both units, the Conditions and Required Actions will apply to both units simultaneously." As a result, applying Technical Speciation requirements to both units simultaneously is required to all requirements associated with an LCO that refers to systems and components shared by both units, irrespective of whether an explicit statement is provided or not. Technical Specification ACTIONS associated with shared systems will continue to be performed for both units simultaneously per the requirements of ITS LCO 3.0.10.

This change is solely a presentation preference and is designated as administrative because it does not result in a technical change to the CTS.

A05 CTS 4.8.2.1.d requires a battery service test for the batteries. The Surveillance specifies that the testing be performed during shutdown conditions and is modified by footnote **. Footnote ** provides an exception to the "during shutdown" condition stating that except that the spare battery bank D-52, and any other battery out of service when spare battery bank D-52 is in service may be tested with simulated loads during operation. ITS Surveillance Requirement (SR) 3.8.4.3 requires a similar verification of battery capacity and is modified by a similar Note. ITS SR 3.8.4.3, Note 2, states that for the battery service test the Surveillance shall not be performed on in-service batteries in MODE 1, 2, 3, or 4; however, credit may be taken for unplanned events that satisfy this SR. This changes the CTS requirement by specifying conditions for when the associated vital batteries are tested.

The purpose of CTS 4.8.2.1.d is to verify the OPERABILITY of the DC Batteries.

The addition of the Note limiting the conditions under which the Surveillance can be performed is acceptable because performance of the Surveillance on in-service batteries could cause perturbations to the electrical distribution system.

Restricting performance of the Surveillance to a battery not in-service during MODES 1, 2, 3, and 4 minimizes challenges to continued steady state operation Turkey Point Unit 3 and Unit 4 Page 2 of 9

DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING and, as a result, the units safety systems. In addition, providing a statement that credit may be taken if the surveillance is performed during unplanned event does not change the CTS because credit can be taken if it can be shown the unplanned event satisfied the surveillance. This change is designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.2.1 states that the DC electrical sources shall be OPERABLE and lists the details of what constitutes a DC electrical source. ITS LCO 3.8.4 states that four DC electrical power trains shall be OPERABLE. This R2 changes the CTS by moving the details of what constitutes an OPERABLE DC electrical power train (battery and charger) from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements for the Vital 125 VDC subsystem trains. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. The program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.2.1 states that the DC electrical sources shall be OPERABLE and includes two footnotes,

  • and #. CTS 3.8.2.1 footnote
  • states that all battery chargers required to satisfy the LCO shall be powered from separate MCCs. Footnote # states that inoperability of the required emergency diesel generators (EDGs) specified in the LCO requirements below does not constitute inoperability of the associated battery chargers or battery banks. ITS LCO 3.8.4 states that Train A and Train B of the DC electrical power subsystem shall be OPERABLE. This changes the CTS by moving the details of what constitutes an OPERABLE battery charger or battery bank from the CTS to the ITS Bases.

Turkey Point Unit 3 and Unit 4 Page 3 of 9

DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirements for the Vital 125 VDC subsystem trains, the relocated information is used to define what is needed for the required trains to be considered OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. The program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.1.a.2 requires verifying total battery terminal voltage to be greater than or equal to 129 volts on float charge and the battery charger(s) output voltage to be 129 volts. ITS SR 3.8.4.1 requires the verification that the battery terminal voltage is greater than or equal to the minimum established float voltage. This changes the CTS by moving the specific values of the minimum established float voltage from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements that the vital battery terminal voltage be greater than or equal to the minimum established float voltage. This change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA04 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 4.8.2.1.a.3 states that if two battery chargers are connected to the battery bank, verify each battery charger is supplying a minimum of 10 amperes, or demonstrate that the battery charger supplying less than 10 amperes will accept and supply the DC bus load independent of its associated battery charger. ITS 3.8.4 surveillances do not include this requirement. This changes the CTS by removal of the battery charger parallel load sharing requirement to the TRM.

The removal of the battery charger parallel load sharing requirement from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications in order to provide adequate protection of public health and safety. The ITS retains the requirement to verify the ability of each battery charger to supply its required load. Also, this change is acceptable because these types of procedural details will be Turkey Point Unit 3 and Unit 4 Page 4 of 9

DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a battery charger parallel load sharing requirement is being removed from the Technical Specifications.

LA05 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.1.c.3 requires that each 400 amp battery charger (associated with Battery Banks 3A and 4B) will supply at least 400 amperes at 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and each 300 amp battery charger (associated with Battery Banks 3B and 4A) will supply at least 300 amperes at 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS SR 3.8.4.2 requires the verification that each battery charger supplies 400 amps (battery chargers associated with Battery Banks 3A and 4B) and 300 amps (battery chargers associated with Battery Banks 3B and 4A) at greater than or equal to the minimum established float voltage for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This changes the CTS by moving the specific values of the minimum established float voltage from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements that the battery charger voltage be greater than or equal to the minimum established float voltage. This change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.8.2.1 states that the following DC electrical sources shall be OPERABLE and lists: a. 125-volt DC Battery Bank 3A or spare battery bank D-52 and associated full capacity charger(s); b. 125-volt DC Battery Bank 3B or spare battery bank D-52 and associated full capacity charger(s); c. 125-volt DC Battery Bank 4A or spare battery bank D-52 and associated full capacity charger(s); and d. 125-volt DC Battery Bank 4B or spare battery bank D-52 and associated full capacity charger(s). Under each DC battery bank and associated charger(s) listing are the associated chargers, identification of the charger's power supply by MCC, and the emergency diesel generator that would provide power to that MCC if needed. CTS Action a provides actions for when a required battery charger is OPERABLE but not capable of being powered from its associated OPERABLE diesel generator(s). In addition, CTS 3.8.2.1, Action b Footnote *, in part, states that each remaining required battery charger is capable of being powered from its associated diesel generator. ITS 3.8.4 states that four DC electrical power trains shall be OPERABLE and only provides Required Actions for inoperable Turkey Point Unit 3 and Unit 4 Page 5 of 9

DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING required battery chargers. This changes the CTS by deleting specific charger power supply requirements in the LCO and Actions if these requirements are not met.

The purpose of CTS 3.4.2.1 LCO is to identify the lowest functional capability or performance levels of equipment required for safe operation of the facility associated with the feature identified (e.g., DC Sources). ITS LCO 3.8.4 identifies the lowest functional capability or performance levels of equipment required for safe operation of the facility associated with the DC Sources as four trains of the DC electrical subsystem and requires them to be OPERABLE.

Relocating the definition of a train is moved to the Bases under DOC LA01. This change is acceptable because the LCO requirements are duplicative of the definition of OPERABLE and Required Actions found in ITS 3.8.1. The ITS definition of OPERABLE states, "A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s)." CTS definition of OPERABLE states, "A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s), and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function(s) are also capable of performing their related support function(s)." In addition, the existing CTS power supply requirements are incorporated into ITS 3.8.1 ACTIONS for when a normal (offsite) or emergency (emergency diesel generator) power source is inoperable. In ITS 3.8.1 Required Actions are provided to perform the determination of OPERABILITY of the redundant systems when a power supply (e.g., EDG) is determined inoperable. Thus, this change is acceptable because the definition of OPERABLE and the Required Actions found in ITS 3.8.1 for an inoperable power source continue to ensure that structures, systems, and components are maintained consistent with the safety analyses and licensing basis. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L02 (Category 3 - Relaxation of Completion Time) CTS 3.8.2.1, ACTION b, states, in R2 part, that with none of the full-capacity chargers associated with a battery bank OPERABLE, restore and at least one charger associated with each battery bank to OPERABLE status within two hours or commence a unit shutdown. ITS 3.8.4, ACTION A, has been added to provide Actions for the condition with one required battery chargers inoperable. ITS 3.8.4, Required Action A.1, requires the restoration of the battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ITS 3.8.4, Required Action A.2, requires the verification that the battery float current is 2 amps once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

ITS 3.8.4, Required Action A.3, requires the restoration of the battery chargers to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This changes the CTS by extending the time a required battery charger may be inoperable.

Turkey Point Unit 3 and Unit 4 Page 6 of 9

DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING The purpose of CTS 3.8.2.1 is to ensure that the two trains of DC electrical power system can supply the associated loads during a design bases accident. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with the safe operation under the specified Condition, considering the OPERABLE status of the redundant systems and features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a design basis accident (DBA) occurring during the repair period. The proposed ITS 3.8.4, ACTION A, provides up to a 72-hour restoration time for an inoperable required battery charger. However, this time is contingent on a focused and tiered approach to assuring adequate battery capability is maintained. The priority for the operator is to minimize the battery discharge, which is required to be terminated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (ITS 3.8.4, Required Action A.1).

Presuming that the battery discharge (if occurring) can be terminated, and that the DC bus remains energized (as required by a separate LCO), there is reasonable basis for extending the restoration time for an inoperable charger beyond the 2-hour limit. The second tiered Action proposes 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to establish that the battery has sufficient capacity to perform its assumed duty cycle (which may involve some recharging of lost capacity that occurred during the initial hours).

Given the choice of a unit shutdown in this condition (as currently required) versus a 12-hour determination (at the end of which it is reasonable to assume the battery can be shown to have its assumed capacity) followed by a 72-hour restoration period, is an acceptable relaxation. Because the focus of this allowance is that the battery capacity be preserved and assured, the means of accomplishing this may be a spare battery charger employed within the initial 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, or the degraded charger that continues to float the battery. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L03 (Category 4 - Relaxation of Required Action) CTS 3.8.2.1, ACTION b, states, in part, that when the required actions of ACTION b are not met within the time specified that the units must be placed in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. ITS 3.8.4, ACTION D, states that with Required Actions and associated Completion Times of the identified Conditions of inoperability not met, to be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> and includes a Note stating that LCO 3.0.4.a is not applicable when entering MODE 4. This changes the CTS by permitting a Required Action end state of HOT SHUTDOWN (MODE 4) rather that an end state of COLD SHUTDOWN (MODE 5).

One purpose of CTS 3.8.2.1, ACTION b, is to provide an end state, a condition that the reactor must be placed in, if the Required Actions, allowing remedial measures to be taken in response to the degraded conditions with continued operation, are not met. End states are usually defined based on placing the unit into a MODE or condition in which the Technical Specification LCO is not applicable. MODE 5 is the current end state for LCOs that are applicable in MODES 1 through 4. This change is acceptable because the risk of the Turkey Point Unit 3 and Unit 4 Page 7 of 9

DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING transition from MODE 1 to MODES 4 or 5 depends on the availability of AC sources and the ability to remove decay heat such that remaining in MODE 4 may be safer. During the realignment from MODE 4 to MODE 5, there is an increased potential for loss of shutdown cooling and loss of inventory events.

Decay heat removal following a loss-of-offsite power event in MODE 5 is dependent on AC power for shutdown cooling whereas, in MODE 4, the turbine driven auxiliary feedwater (AFW) pump will be available. Therefore, transitioning to MODE 5 is not always the appropriate end state from a risk perspective.

Thus, for specific TS conditions, Westinghouse Topical Report WCAP-16294-A, Revision 1 (ADAMS Accession No. ML103430249), justifies MODE 4 as an acceptable alternate end state to Mode 5. The proposed change to the Technical Specifications will allow time to perform short-duration repairs, which currently necessitate exiting the original mode of applicability. The MODE 4 Technical Specification end state is applied, and risk is assessed and managed in accordance with Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." This proposed change is consistent with NRC approved TSTF-432-A, Revision 1 (ADAMS Accession No. ML103360003), noticed for availability by the NRC in the Federal Register (77 FR 27814) on May 11, 2012.

The NRC's approval of WCAP-16294-A included four limitations and conditions on its use as identified in Section 4.0 of the NRC Safety Evaluation associated with WCAP-16294-A. Implementation of these stipulations were addressed in the Bases of TSTF-432-A. Florida Power & Light Company implemented these limitations and conditions at PTN in the adoption of the associated TSTF-432-A Bases. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L04 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.2.1.c.3 requires, in part, each 400 amp battery charger (associated with Battery Banks 3A and 4B) will supply at least 400 amperes at 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and each 300 amp battery charger (associated with Battery Banks 3B and 4A) will supply at least 300 amperes at 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

ITS SR 3.8.4.2 includes a similar test. In addition, the SR provides an alternative test method. This test method requires verification that each battery charger can recharge the battery to the fully charge state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state. This changes the CTS by allowing an alternate test method that is not currently allowed.

The purpose of CTS 4.8.2.1.c.3 is to verify the required 125 V DC battery chargers can recharge the respective batteries following a loss of offsite power event. This change is acceptable because the relaxed SR acceptance criteria are adequate to verify the equipment used to meet the LCO can perform its required functions. This alternate test provides an acceptable method for determining charger capability by recharging a discharge battery within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the required loads. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Turkey Point Unit 3 and Unit 4 Page 8 of 9

DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING L05 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.8.2.1.d requires, in part, a verification of the station battery capacity when the battery is subjected to a service test. CTS 4.8.2.1.f allows substitution of a performance discharge test in lieu of the battery service test once per 60-month interval. ITS SR 3.8.4.3 is modified by Note 1 which allows the modified performance discharge test in SR 3.8.6.6 to be performed in lieu of the service test in SR 3.8.4.3. This changes the CTS by allowing a modified performance discharge test to be substituted for a service test for any performance of the Surveillance, instead of the current once per 60 months.

This change is acceptable because the relaxed SR acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. The modified performance discharge test is a test of the battery capacity and its ability to support a high rate, short duration load (usually the highest rate of the duty cycle). As stated in the Bases for ITS SR 3.8.6.6, the battery terminal voltage for the modified performance discharge test must remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test. This modified test has been shown to be as effective in determining battery capacity as the standard service test. This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.

Turkey Point Unit 3 and Unit 4 Page 9 of 9

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating Four trains 3.8.2.1 LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be 1 OPERABLE.

Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME required Action B A. One [or two] battery A.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 3

charger[s] on one voltage to greater than or subsystem inoperable. equal to the minimum 1 train established float voltage.

AND A.2 Verify battery float current Once per [12] hours 3

[2] amps.

AND required A.3 Restore battery charger[s] [72] hours 1 3 to OPERABLE status.

[OR 3 In accordance with the Risk Informed Completion Time Program] 3

[B. One [or two] batter[y][ies B.1 Restore batter[y][ies] to [2] hours ]

on one subsystem] OPERABLE status.

inoperable. [OR INSERT 1 In accordance with 2 the Risk Informed Completion Time Program]

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.4-1 Rev. 5.0 1

CTS ITS 3.8.4 2

INSERT 1 B. --------NOTE------------ B.1 Restore DC electrical 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ACTION b and Only applicable when power train to OPERABLE footnote

  • opposite unit is not in status. OR MODE 1, 2, 3, or 4.

In accordance with the Risk Informed One DC electrical power Completion Time train inoperable for Program reasons other than Condition A.

Insert Page 3.8.4-1

CTS DC Sources - Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION B C. One DC electrical power C.1 Restore DC electrical [2] hours 3 subsystem inoperable power subsystem to 1 train train for reasons other than OPERABLE status. [OR 3 Condition A [or B].

In accordance with the Risk Informed Completion Time Program] 3 12 ACTION B D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 2 Associated Completion Time not met. AND D.2 --------------NOTE--------------

LCO 3.0.4.a is not applicable when entering MODE 4.

18 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.2.1.a.2) SR 3.8.4.1 Verify battery terminal voltage is greater than or [ 7 days equal to the minimum established float voltage. 3 OR In accordance with the Surveillance Frequency Control Program ] 3 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.4-2 Rev. 5.0 1

CTS DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY INSERT 2 4.8.2.1.c.3) SR 3.8.4.2 Verify each battery charger supplies [400] amps at [ [18] months 2 greater than or equal to the minimum established 3 float voltage for [8] hours. OR OR In accordance with the DOC L04 Verify each battery charger can recharge the battery Surveillance to the fully charged state within [24] hours while Frequency 3

supplying the largest combined demands of the Control Program ]

various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

4.8.2.1.d SR 3.8.4.3 ------------------------------NOTES-----------------------------

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3.
2. This Surveillance shall not normally be 2 performed in MODE 1, 2, 3, or 4. However, on in-service batteries portions of the Surveillance may be performed 4 to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and [ [18] months maintain in OPERABLE status, the required 3 emergency loads for the design duty cycle when OR subjected to a battery service test.

In accordance with the Surveillance Frequency Control Program ] 3 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.4-3 Rev. 5.0 1

CTS ITS 3.8.4 2

INSERT 2 4.8.2.1.c.3) (battery chargers associated with Battery Banks 3A and 4B) and 300 amps (battery chargers associated with Battery Banks 3B and 4A)

Insert Page 3.8.4-3

JUSTIFICATION FOR DEVIATIONS ITS 3.8.4, DC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. Changes made to reflect the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS).
3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
4. No portion of the battery service test can be performed on in-service batteries in MODES 1, 2, 3, or 4 without making the battery inoperable. The battery service test is normally performed by removing a battery from service and placing the spare battery in-service. Furthermore, the battery service test is not performed in steps, where only part of the test can be performed. Therefore, this part of the Note has been deleted.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

DC Sources - Operating B 3.8.4 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.4 DC Sources - Operating BASES BACKGROUND The station DC electrical power system provides the AC emergency power system with control power. It also provides both motive and control power to selected safety related equipment and preferred AC vital bus power (via inverters). As required by 10 CFR 50, Appendix A, 39 1 GDC 17 (Ref. 1), the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The DC electrical power system also conforms to the recommendations of Regulatory Guide 1.6 (Ref. 2) and IEEE-308 (Ref. 3). 1 as described in the UFSAR (Ref. 4)

INSERT 1 The [125/250] VDC electrical power system consists of two independent and redundant safety related Class 1E DC electrical power subsystems

([Train A and Train B]). Each subsystem consists of [two] 125 VDC batteries [(each battery [50]% capacity)], the associated battery charger(s) for each battery, and all the associated control equipment and interconnecting cabling.

[ The 250 VDC source is obtained by use of the two 125 VDC batteries 1 connected in series. Additionally there is [one] spare battery charger per subsystem, which provides backup service in the event that the preferred battery charger is out of service. If the spare battery charger is substituted for one of the preferred battery chargers, then the requirements of independence and redundancy between subsystems are maintained. ]

both the normal and alternate During normal operation, the [125/250] VDC load is powered from the 2 battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC load is automatically powered from the station batteries.

of the The [Train A and Train B] DC electrical power subsystems provide the 1 control power for its associated Class 1E AC power load group, [4.16] kV 2 switchgear, and [480] V load centers. The DC electrical power s

subsystems also provide DC electrical power to the inverters, which in 1 turn power the AC vital buses.

The DC power distribution system is described in more detail in Bases for LCO 3.8.9, "Distribution System - Operating," and LCO 3.8.10, "Distribution Systems - Shutdown."

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-1 Rev. 5.0 1

B 3.8.4 1

INSERT 1 The DC electrical power sources are shared between the units. The DC electrical power R2 system contains five safety related 125V batteries and associated battery chargers. Two battery banks (Train A and Train B) are associated with each unit, one 1800 ampere-hour (AH) and one 1200 AH, and a spare 1945 AH battery bank that can be substituted, to allow for testing or maintenance, for any of the other four battery banks. Each 1800 AH battery bank has two safety related full capacity 400 ampere solid-state battery chargers associated with it; a normal and an alternate charger. Each 1200 AH battery bank has two safety related full capacity 300 ampere solid-state battery chargers associated with it; a normal and an alternate charger. The spare battery bank is normally isolated from the vital DC buses and maintained in a fully charged condition by a non-safety related battery charger. Each battery has been sized to support operation of its required loads for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without terminal voltage falling below its minimum required value.

Each normal battery charger is powered by a vital motor control center (MCC) of the same train and unit of its associated battery. The alternate battery chargers for both battery banks are powered by the vital swing MCC of the opposite unit. Unit 3 DC battery chargers 3A2 and 3B2 are powered from Unit 4 via swing MCC 4D, and Unit 4 DC battery chargers 4A2 and 4B2 are powered from Unit 3 via swing MCC 3D.

Insert Page B 3.8.4-1

DC Sources - Operating B 3.8.4 BASES BACKGROUND (continued)

Each 125/250 VDC battery is separately housed in a ventilated room train 1 apart from its charger and distribution centers. Each subsystem is located in an area separated physically and electrically from the other train subsystem to ensure that a single failure in one subsystem does not train 1 cause a failure in a redundant subsystem. [There is no sharing between 2

redundant Class 1E subsystems, such as batteries, battery chargers, or distribution panels.]

Each battery has adequate storage capacity to meet the duty cycle(s)

U discussed in the FSAR, Chapter [8] (Ref 4). The battery is designed with 1 2 additional capacity above that required by the design duty cycle to allow for temperature variations and other factors.

The batteries for Train A and Train B DC electrical power subsystems are sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100%

design demand. The minimum design voltage limit is [105/210 V]. 2 The battery cells are of flooded lead acid construction with a nominal specific gravity of [1.215]. This specific gravity corresponds to an open 124 circuit battery voltage of approximately 120 V for a [58] cell battery (i.e., 1 2 60 cell voltage of [2.065] volts per cell (Vpc)). The open circuit voltage is the voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage [2.065] Vpc, the battery cell will 3

maintain its capacity for [30] days without further charging per manufacturer's instructions. Optimal long term performance however, is 2.17 to 2.25 obtained by maintaining a float voltage [2.20 to 2.25] Vpc. This provides 2 2.21 adequate over-potential, which limits the formation of lead sulfate and self discharge. The nominal float voltage of [2.22] Vpc corresponds to a total 132.6 float voltage output of [128.8] V for a [58] cell battery as discussed in the 2 battery vendor FSAR, Chapter [8] (Ref. 4). 60 1 10 R2 technical manual Each Train A and Train B DC electrical power subsystem battery charger has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each battery charger also has sufficient excess capacity to restore the battery from the design minimum charge to its fully charged state within [24] hours while supplying normal 2 U

steady state loads discussed in the FSAR, Chapter [8] (Ref. 4). 1 The battery charger is normally in the float-charge mode. Float-charge is the condition in which the charger is supplying the connected loads and the battery cells are receiving adequate current to optimally charge the battery. This assures the internal losses of a battery are overcome and the battery is maintained in a fully charged state.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-2 Rev. 5.0 1

DC Sources - Operating B 3.8.4 BASES BACKGROUND (continued)

When desired, the charger can be placed in the equalize mode. The equalize mode is at a higher voltage than the float mode and charging current is correspondingly higher. The battery charger is operated in the equalize mode after a battery discharge or for routine maintenance.

Following a battery discharge, the battery recharge characteristic accepts current at the current limit of the battery charger (if the discharge was significant, e.g., following a battery service test) until the battery terminal voltage approaches the charger voltage setpoint. Charging current then reduces exponentially during the remainder of the recharge cycle. Lead-calcium batteries have recharge efficiencies of greater than 95%, so once at least 105% of the ampere-hours discharged have been returned, the battery capacity would be restored to the same condition as it was prior to the discharge. This can be monitored by direct observation of the exponentially decaying charging current or by evaluating the amp-hours discharged from the battery and amp-hours returned to the battery.

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient 14 U

SAFETY analyses in the FSAR, Chapter [6] (Ref. 5) and Chapter [15] (Ref. 6), 2 1 ANALYSES assume that Engineered Safety Feature (ESF) systems are OPERABLE.

The DC electrical power system provides normal and emergency DC EDG electrical power for the DGs, emergency auxiliaries, and control and 1 switching during all MODES of operation.

The OPERABILITY of the DC sources is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining the DC sources OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC power or all onsite AC power and 1
b. A worst-case single failure.

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

four trains, which are shared between Units 3 and 4 LCO The DC electrical power subsystems, each subsystem consisting of [two] 1 R2 INSERT 2 2 batteries, battery charger [for each battery] and the corresponding control equipment and interconnecting cabling supplying power to the associated train bus within the subsystem are required to be OPERABLE to ensure the 1 availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a train postulated DBA. Loss of any DC electrical power subsystem does not 1 prevent the minimum safety function from being performed (Ref. 4).

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-3 Rev. 5.0 1

B 3.8.4 2

INSERT 2 one battery, one required battery charger Insert Page B 3.8.4-3

DC Sources - Operating B 3.8.4 BASES LCO (continued) train An OPERABLE DC electrical power subsystem requires all required 1 batteries and respective chargers to be operating and connected to the associated DC bus(es). INSERT 3 APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure safe unit operation and to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and
b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.

The DC electrical power requirements for MODES 5 and 6 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown."

ACTIONS A.1, A.2, and A.3 train required Condition A represents one subsystem with one [or two] battery chargers 1 2 inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, 2 the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.

REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> plus the time experienced to accomplish the exponential charging 4 current portion of the battery charge profile following the service test (SR 3.8.4.3).

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-4 Rev. 5.0 1

B 3.8.4 1

INSERT 3 For a train to be considered OPERABLE requires the following alignments:

a. Train 3A requires 125 VDC Battery Bank 3A or spare battery bank D-52 and associated full capacity charger(s) 3A1 or 3A2,
b. Train 3B requires 125 VDC Battery Bank 3B or spare battery bank D-52 and associated full capacity charger(s) 3B1 or 3B2, R2
c. Train 4A requires 125 VDC Battery Bank 4A or spare battery bank D-52 and associated full capacity charger(s) 4A1 or 4A2, and
d. Train 4B requires 125 VDC Battery Bank 4B or spare battery bank D-52 and associated full capacity charger(s) 4B1 or 4B2.

For the purposes of meeting the LCO with an alternate charger (A2 or B2) in service, the following criteria must be met to ensure electrical separation and redundancy:

a. Only one alternate battery charger may be credited at a time (A2 or B2 charger) and
b. Automatic transfer capability must be maintained on the swing load center associated with the swing MCC supplying the alternate battery charger.

If two normal chargers are inoperable and the alternate chargers are in service from a single swing MCC, one DC electrical power train must be considered inoperable and Condition A entered. In addition, if the automatic transfer capability associated with the swing MCC is not available when an alternate charger is in service, the alternate charger may not be credited to meet the LCO.

Insert Page B 3.8.4-4

DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown 2 with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within [12] hours (Required Action A.2). 2 Required Action A.2 requires that the battery float current be verified as less than or equal to [2] amps. This indicates that, if the battery had been 2 discharged as the result of the inoperable battery charger, it is now fully capable of supplying the maximum expected load requirement. The

[2] amp value is based on returning the battery to [95]% charge and assumes a [5]% design margin for the battery. If at the expiration of the 2

initial [12] hour period the battery float current is not less than or equal to

[2] amps this indicates there may be additional battery problems and the battery must be declared inoperable.

REVIEWERS NOTE-----------------------------------

Any licensee wishing to adopt Completion Time greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for Required Action A.3 will need to demonstrate that the longer Completion Time is appropriate for the plant in accordance with the guidance in 4

Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," and RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis."

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-5 Rev. 5.0 1

DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

Alternatively, a 7 day Completion Time can be justified by an acceptable method, such as a regulatory commitment that an alternate means to charge the batteries will be available that is capable of being supplied 4 power from a power source that is independent of the offsite power supply. Otherwise, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time must be adopted.

Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. [Alternatively, a Completion Time can be 2 determined in accordance with the Risk Informed Completion Time Program.] This action is applicable if an alternate means of restoring 2 battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The [72] hour Completion Time reflects a 2 reasonable time to effect restoration of the qualified battery charger to OPERABLE status.

B.1 1

REVIEWERS NOTES---------------------------------

1. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Times of Required Actions B.1 and C.1 are in brackets. Any licensee wishing to request a longer Completion Time will need to demonstrate that the longer Completion Time is appropriate for the plant in accordance with the guidance in RG 1.177 and RG 1.174.
2. Condition B is included if Required Action B.1 (one [or two] 4 batter[y][ies on one subsystem] inoperable) and Required Action C.1 (one DC electrical power subsystem inoperable for reasons other than Condition A [or B]) would have different Completion Times. If the plant design supports different Completion Times when a battery is inoperable but the charger is OPERABLE, then Condition B is used. If not, Condition B is deleted and only Condition C is used.

Condition B represents one subsystem with one [or two] batter[y][ies]

inoperable. With one [or two] batter[y][ies] inoperable, the DC bus is being supplied by the OPERABLE battery charger[s]. Any event that results in a loss of the AC bus supporting the battery charger[s] will also result in loss of DC to that subsystem. Recovery of the AC bus, 1 especially if it is due to a loss of offsite power, will be hampered by the fact that many of the components necessary for the recovery (e.g., diesel generator control and field flash, AC load shed and diesel generator output circuit breakers, etc.) likely rely upon the batter[y][ies]. In addition Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-6 Rev. 5.0 1

DC Sources - Operating B 3.8.4 BASES ACTIONS (continued) the energization transients of any DC loads that are beyond the capability of the battery charger[s] and normally require the assistance of the batter[y][ies] will not be able to be brought online. The [2] hour limit allows sufficient time to effect restoration of an inoperable battery given that the majority of the conditions that lead to battery inoperability (e.g.,

1 loss of battery charger, battery cell voltage less than [2.07] V, etc.) are identified in Specifications 3.8.4, 3.8.5, and 3.8.6 together with additional specific Completion Times. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.]

INSERT 4 5

C.1 train Condition C represents one subsystem with a loss of ability to completely 5 1 respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for train complete loss of DC power to the affected subsystem. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is 1 panel consistent with the allowed time for an inoperable DC distribution subsystem. [Alternatively, a Completion Time can be determined in 2 accordance with the Risk Informed Completion Time Program.]

train If one of the required DC electrical power subsystems is inoperable for 1 reasons other than Condition A or B (e.g., inoperable battery charger and associated inoperable battery), the remaining DC electrical power train subsystem has the capacity to support a safe shutdown and to mitigate 1 an accident condition. Since a subsequent worst-case single failure could, however, result in the loss of the minimum necessary DC electrical 1 subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time is based on 8

Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem 1 train and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

D.1 and D.2 5 train If the inoperable DC electrical power subsystem cannot be restored to s 1 OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this s

status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to 5

MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. 12 18 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-7 Rev. 5.0 1

B 3.8.4 5

INSERT 4 B.1 Condition B represents one train with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected subsystem. The allowable Completion Time is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the opposite unit is not in MODES 1, 2, 3, or 4 to allow for required battery maintenance without requiring both units to be shutdown. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

If one of the required DC electrical power trains is inoperable for reasons other than Condition A (e.g., inoperable battery charger and associated inoperable battery), the remaining DC electrical power trains have the capacity to support a safe shutdown and to mitigate an accident condition.

Condition B is modified by a Note stating that this Condition is only applicable when the opposite unit is not in MODE 1, 2, 3, or 4. R2 Insert Page B 3.8.4-7

DC Sources - Operating B 3.8.4 BASES ACTIONS (continued)

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power sequential conditions in an orderly manner and without challenging plant systems.

The Completion Time to bring the unit to MODE 5 is consistent with the 1 time required in Regulatory Guide 1.93 (Ref. 7).

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady train state loads of the associated DC subsystem. On float charge, battery 1 cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by 2.17 the battery manufacturer ([2.20] Vpc times the number of connected cells 130.2 2 or [127.6] V for a 58 cell battery at the battery terminals). This voltage 1 60 maintains the battery plates in a condition that supports maintaining the grid life. [ The 7 day Frequency is consistent with manufacturer 2

recommendations.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-8 Rev. 5.0 1

DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

OR 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.8.4.2 This SR verifies the design capacity of the battery chargers. According to Regulatory Guide 1.32 (Ref. 9), the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensures that these requirements can be satisfied.

This SR provides two options. One option requires that each battery INSERT 5 charger be capable of supplying [400] amps at the minimum established 2

float voltage for [8] hours. The ampere requirements are based on the output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time period is sufficient for the charger temperature to have stabilized and to 6 have been maintained for at least [2] hours.

The other option requires that each battery charger be capable of recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur). This level of loading may not normally be available following the battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. The battery is recharged when the measured charging current is [2] amps. 2 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-9 Rev. 5.0 1

B 3.8.4 2

INSERT 5 400 amps (battery chargers associated with Battery Banks 3A and 4B) and 300 amps (battery chargers associated with Battery Banks 3B and 4A)

Insert Page B 3.8.4-9

DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these [18 month]

intervals. In addition, this Frequency is intended to be consistent with 2 expected fuel cycle lengths.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.8.4.3 A battery service test is a special test of the battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements as specified in Reference 4.

[ The Surveillance Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 9) and Regulatory Guide 1.129 (Ref. 10), which state that the battery service test should be performed during refueling operations, or at some other outage, with 2 intervals between tests not to exceed [18 months].

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-10 Rev. 5.0 1

DC Sources - Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.

on an in-service battery The reason for Note 2 is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the 5 potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.

1967 proposed GDC 39, REFERENCES 1. 10 CFR 50, Appendix A, GDC 17. Emergency Power for Engineered 1 Safety Features

2. Regulatory Guide 1.6, March 10, 1971.

1971

3. IEEE-308-[1978]. 2 U
4. FSAR, Chapter [8]. 1 2 U
5. FSAR, Chapter [6]. 1 2 U 14
6. FSAR, Chapter [15] . 1 2
7. Regulatory Guide 1.93, December 1974. 1
8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes 1 to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.
9. Regulatory Guide 1.32, February 1977. Vendor Technical Manual 1

V000468, "60 NCX-27 On Two Tier R2

10. Regulatory Guide 1.129, December 1974. Racks (Seismic)," May 2010. 1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-11 Rev. 5.0 1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.4 BASES, DC SOURCES - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. These battery design values have been deleted because this type of information is not necessary to provide sufficient background for this Specification.
4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
5. Changes have been made to be consistent with changes made to the Specifications.
6. The information in the Bases of ISTS SR 3.8.4.2 related to battery charger temperature stabilization is not included in the ITS Bases because it cannot be R2 confirmed that the historical basis for the 8-hour duration specified in the PTN current Technical Specifications includes consideration of charger temperature stabilization.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.4, DC SOURCES - OPERATING There are no specific No Significant Hazards Considerations for this Specification.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

ATTACHMENT 5 ITS 3.8.5, DC SOURCES - SHUTDOWN

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS ITS 3.8.5 A01 D.C. SOURCES SHUTDOWN A02 LIMITING CONDITION FOR OPERATION trains of the DC electrical power subsystem LA01 LCO 3.8.5 3.8.2.2 As a minimum, three 125 volt battery banks, each with at least one associated full capacity charger capable of being powered by an OPERABLE diesel generator, shall be OPERABLE. A03 M01 Applicability APPLICABILITY: MODES 5* and 6*. , During movement of irradiated fuel assemblies.

Add proposed Actions Note M01 ACTION:

Add proposed Action A Action B With one or more of the required 125 volt battery banks or required associated full-capacity chargers inoperable L01 or not capable of being powered from an OPERABLE diesel generator, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel; initiate corrective action to restore the required battery banks and associated full-capacity chargers to OPERABLE status as soon as possible, and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the Reactor Coolant System through at least a 2.2 square L02 inch vent.

Add proposed Required Actions B.1 and B.2.2 L03 SURVEILLANCE REQUIREMENTS Add proposed SR 3.8.5.1 Note L04 SR 3.8.5.1 4.8.2.2 The above required 125 volt battery banks and associated full-capacity chargers shall be demonstrated OPERABLE in accordance with Specification 4.8.2.1.

A03

  • CAUTION - If the opposite unit is in MODES 1, 2, 3 or 4, see the corresponding Limiting Condition for Operation 3.8.2.1.

TURKEY POINT - UNITS 3 & 4 3/4 8-17 AMENDMENT NOS. 138 AND 133 Page 1 of 1

DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.2.2 requires, in part, three 125 volt battery banks, each with at least one associated full capacity charger capable of being powered by an OPERABLE Emergency Diesel Generator (EDG). ITS Limiting Condition for Operation (LCO) 3.8.5 requires three trains of the DC electrical power subsystem to be OPERABLE. This changes the CTS by combining the individual components, battery bank, charger, and EDG requirements into one separate Specification.

The change is acceptable because no changes are made to CTS requirements.

The change in format from the CTS to the ITS maintains the technical requirements. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 3.8.2.2 (ITS 3.8.5) is applicable in MODES 5 and 6. The CTS 3.8.2.2 Applicability is modified by a Note which states, "CAUTION - If the opposite unit is in MODES 1, 2, 3, or 4, see the corresponding Limiting Condition for Operation 3.8.2.1." ITS 3.8.5 does not contain a similar Note. This changes the CTS by deleting a requirement that is redundant to CTS 3.0.5, which is retained in ITS.

The purpose of the CTS 3.8.2.2 Applicability Note is to ensure appropriate action requirements are performed for equipment shared between both units when required for a specific MODE of operation. This Note is redundant to the generic requirement provided in CTS 3.0.5 (ITS LCO 3.0.10) and, therefore, is not necessary. CTS 3.0.5 states, in part, "Limiting Conditions for Operation including the associated ACTION requirements shall apply to each unit individually unless otherwise indicated This requirement is retained in ITS LCO 3.0.10. As a result, Technical Specification requirements are applicable to each unit and apply, based on the units applicable MODE, to the requirements associated with an LCO that refers to systems and components shared by both units, irrespective of whether an explicit statement is provided or not. The appropriate Technical Specification ACTIONS associated with shared systems will continue to be performed for each unit based on the units applicable MODE or specified condition per the requirements of ITS LCO 3.0.10. This change is designated as an administrative change and is acceptable because the change does not result in technical changes to the CTS.

Turkey Point Unit 3 and Unit 4 Page 1 of 6

DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN MORE RESTRICTIVE CHANGES M01 CTS 3.8.2.2 is applicable in MODES 5 and 6. ITS 3.8.5 is applicable in MODES 5 and 6 and during movement of irradiated fuel assemblies. A Note has been added to the ACTIONS which states that LCO 3.0.3 is not applicable. This changes the CTS by adding the Applicability of during movement of irradiated fuel assemblies and adds the Note to the ACTIONS stating that LCO 3.0.3 is not applicable.

This change is acceptable because the proposed requirements are necessary to ensure the DC electrical power sources are OPERABLE to support equipment required to be OPERABLE during movement of irradiated fuel assemblies.

Movement of fuel normally occurs during MODES 5 and 6, however, it can also occur outside of containment in other plant MODES (MODES 1, 2, 3, and 4) or other conditions (i.e., reactor defueled). This Specification is needed to ensure the appropriate DC electrical power source requirements are specified during fuel handling and ensure the appropriate actions are taken (i.e., stop fuel movement) when the minimum electrical supplies are not available. This change adds a clarification Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable and would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with the ITS 3.8.5 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shut down but would not require suspension of activities with a potential for releasing radioactive materials. This change is designated as more restrictive because the ITS requires the equipment to be OPERABLE during movement of irradiated fuel assemblies both inside and outside of the containment, not only in MODES 5 and 6.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.2.2 states, in part, three 125 volt battery banks, each with at least one associated full capacity charger capable of being powered by an OPERABLE EDG, shall be OPERABLE. ITS LCO 3.8.5 requires three trains of the DC electrical power subsystem to be OPERABLE. This changes the CTS by moving the details of a train of the DC electrical power subsystem from the CTS to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate Turkey Point Unit 3 and Unit 4 Page 2 of 6

DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN protection of public health and safety. The ITS still retains the OPERABILITY requirements for electrical power trains. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. The program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.8.2.2 ACTION states, in R2 part, that with one or more of the required associated full-capacity chargers inoperable or not capable of being powered from an OPERABLE EDG, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel; initiate corrective action to restore the required battery banks and associated full-capacity chargers to OPERABLE status as soon as possible. ITS 3.8.5, Required Action A.1, requires the restoration of the battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ITS 3.8.5, Required Action A.2, requires the verification that the battery float current is 2 amps once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.8.5, Required Action A.3, requires the restoration of the battery chargers to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This changes the CTS by extending the time a required battery charger may be inoperable.

The purpose of CTS 3.8.2.2 is to ensure that the three trains of DC electrical power system can supply the associated loads. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with the safe operation under the specified Condition, considering the OPERABLE status of the redundant systems and features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a Design Basis Accident (DBA) occurring during the repair period. The proposed ITS 3.8.5, ACTION A, provides up to a 72-hour restoration time for an inoperable required battery charger. However, this time is contingent on a focused and tiered approach to assuring adequate battery capability is maintained. The priority for the operator is to minimize the battery discharge, which is required to be terminated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (ITS 3.8.5, Required Action A.1). Presuming that the battery discharge (if occurring) can be terminated, and that the DC bus remains energized (as required by a separate LCO), there is reasonable basis for extending the restoration time for an inoperable charger beyond the 2-hour limit.

The second tiered action proposes 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to establish that the battery has sufficient capacity to perform its assumed duty cycle (which may involve some recharging of lost capacity that occurred during the initial hours). Given the choice of a unit shutdown in this condition (as currently required) versus a 12-hour determination (at the end of which it is reasonable to assume the battery can be shown to have its assumed capacity) followed by a 72-hour restoration Turkey Point Unit 3 and Unit 4 Page 3 of 6

DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN period, is an acceptable relaxation. Because the focus of this allowance is that the battery capacity be preserved and assured, the means of accomplishing this may be a spare battery charger employed within the initial 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, or the degraded charger that continues to float the battery. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 3 - Relaxation of Completion Time) CTS 3.8.2.2 ACTION requires that with one or more of the required 125 volt battery banks or required associated full-capacity chargers inoperable or not capable of being powered from an OPERABLE EDG, the Reactor Coolant System (RCS) must be depressurized and vented within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> through a 2.2 square inch vent.

ISTS 3.8.5 does not include this Required Action. ITS LCO 3.4.12, "Overpressure Mitigation System," provides requirements for RCS pressure relief when in MODES 4, 5, or 6 to depressurize and establish an RCS vent of 2.2 square inches within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the other pressure relief methods are R2 incapable of limiting pressure. This changes the CTS by relying on ITS LCO 3.4.12 to provide the Required Actions and allowing a longer Completion Time to depressurize the RCS and establish a 2.2 square inch RCS vent.

The purpose of CTS 3.8.2.2 ACTION is to provide remedial actions to be taken in response to the loss of a required DC train while in MODE 5 or 6. One of these remedial actions is to depressurize and vent the RCS through at least a 2.2 square inch vent, which is being proposed for deletion. This change is acceptable because the CTS 3.8.2.2 action to depressurize and vent the RCS is duplicative of the ITS LCO 3.4.12 Required Action to depressurize and vent the RCS. In addition, ITS 3.4.12 Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the allowed Completion Time.

This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L03 (Category 4 - Relaxation of Required Action) CTS 3.8.2.2 ACTION states, in part, that with one or more of the required 125 volt battery banks or required associated full-capacity chargers inoperable or not capable of being powered from an OPERABLE EDG, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel.

ITS 3.8.5, Required Actions B.1, B.2.1, and B.2.2, provide Actions to be performed under similar conditions. These ITS Required Actions state to declare affected required feature(s) inoperable, or to suspend movement of irradiated fuel assemblies and suspend operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN (SDM) or boron concentration. This changes the CTS Actions by deleting the requirement to suspend CORE ALTERATIONS and to clarify to only suspend positive reactivity additions when it could result in loss of required SDM or boron concentration.

The purpose of the CTS 3.8.2.2 ACTION is to minimize the possibility of an event that may need the DC source to mitigate the consequences of the event. CORE Turkey Point Unit 3 and Unit 4 Page 4 of 6

DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN ALTERATIONS is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel." CORE ALTERATIONS only occur when the reactor vessel head is removed and only applies in MODE 6. There is only one accident considered during MODE 6 that involves CORE ALTERATIONS: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building.

Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, will not prevent or impair the mitigation of a fuel handling accident.

ITS 3.8.5 retains the requirement to suspend movement of irradiated fuel assemblies in ITS 3.8.5, Required Action B.2.1 (for one or more inoperable DC electrical power trains). Therefore, because the only CORE ALTERATION analyzed in the safety analysis and potentially affected by a loss of a DC source is covered by the ITS Required Actions, deleting the reference to "CORE ALTERATIONS" is acceptable. Additionally, CORE ALTERATIONS that may be R2 capable of damaging a fuel assembly prior to the 72-hour decay period is improbable because the physical time required to perform plant shutdown, cooldown, depressurize the Reactor Coolant System, and the additional operations required to expose the irradiated fuel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

CTS 3.8.2.2 ACTION also requires that with less than the above minimum required DC electrical power sources OPERABLE, immediately suspend all operations involving positive reactivity changes while ITS 3.8.5, Required Action B.2.2, requires only suspending operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. This change is acceptable because it allows for positive reactivity additions that do not result in loss of required SDM or boron concentration (e.g., water addition or temperature change) assuring continued safe operation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L04 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.2 requires that R2 the required 125 volt battery banks and associated full-capacity chargers be demonstrated OPERABLE in accordance with Specification 4.8.2.1. ITS Surveillance Requirement (SR) 3.8.5.1 requires SR 3.8.4.1, SR 3.8.4.2, and SR 3.8.4.3 to be applicable. However, a Note has been added that states ITS SRs 3.8.4.2 and 3.8.4.3 are not required to be performed. This changes the CTS by allowing certain SRs not to be performed.

The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required. This change is acceptable because it has been determined that the relaxed SR acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This Turkey Point Unit 3 and Unit 4 Page 5 of 6

DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

Turkey Point Unit 3 and Unit 4 Page 6 of 6

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown 3.8.2.2 LCO 3.8.5 [DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."]

Three trains of the

[One DC electrical power subsystem shall be OPERABLE.]

REVIEWER'S NOTE-----------------------------------

This second option above applies for plants having a pre-ITS licensing 1 basis (CTS) for electrical power requirements during shutdown conditions that required only one DC electrical power subsystem to be OPERABLE.

Action A the bracketed optional wording in Condition B are also eliminated for this case. The first option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem support as is required for power operating conditions.

Applicability APPLICABILITY: MODES 5 and 6, DOC M01 During movement of [recently] irradiated fuel assemblies. 2 ACTIONS

NOTE-----------------------------------------------------------

DOC M01 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME required

[A. One [or two] battery A.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> charger[s on one voltage to greater than or 2 subsystem] inoperable. equal to the minimum DOC L01 train established float voltage.

AND AND The redundant ies subsystem battery and A.2 Verify battery float current Once per [12] hours 3 2

charger[s] OPERABLE. [2] amps.

required AND Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.5-1 Rev. 5. 0 3

CTS DC Sources - Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore battery charger[s] [72] hours ] 2 to OPERABLE status.

Action B. One [or more] required B.1 Declare affected required Immediately 2 DC electrical power feature(s) inoperable.

trains subsystem[s] inoperable 3 2

[for reasons other than OR Condition A.

B.2.1 Suspend movement of Immediately DOC L03 OR [recently] irradiated fuel 2 assemblies.

Required Actions and associated Completion AND Time of Condition A not met]. B.2.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND B.2.3 Initiate action to restore Immediately required DC electrical trains power subsystems to 3 OPERABLE status.

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.5-2 Rev. 5. 0 3

CTS DC Sources - Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.2.2 SR 3.8.5.1 -------------------------------NOTE------------------------------

The following SRs are not required to be performed:

DOC L04 SR 3.8.4.2 and SR 3.8.4.3.

For DC sources required to be OPERABLE, the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.5-3 Rev. 5. 0 3

JUSTIFICATION FOR DEVIATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN

1. The first bracketed optional Improved Standard Technical Specification (ISTS)

Limiting Condition for Operation (LCO) 3.8.5 and "Reviewers Note" have been deleted because the current licensing basis requires three DC electrical power battery banks and associated equipment to be OPERABLE not the four required during power operation. The second bracketed option was selected for use even though more than one DC electrical power system train is required to be OPERABLE because of its similarity to the Current Technical Specifications (CTS). ISTS 3.8.5 ACTION A has been retained because three DC electrical power trains are specified in the LCO.

2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

DC Sources - Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."

APPLICABLE U The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), 14 2 1 ANALYSES assume that Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial 2 assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 5 and 6 and during movement of [recently] irradiated fuel 1 assemblies ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling recently irradiated fuel. Due to radioactive decay, DC electrical power is only required to mitigate fuel handling 1 accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many DBAs that are analyzed in MODES [1, 2, 3, and 4] have no specific analyses in MODES 1

[5 and 6] because the energy contained within the reactor pressure Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.5-1 Rev. 5.0 2

DC Sources - Shutdown B 3.8.5 BASES APPLICABLE SAFETY ANALYSES (continued) boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Three trains of the LCO train The DC electrical power subsystems, [each required ] [the required] 2 1

[subsystem consisting of two batteries, one battery charger per battery, and the corresponding control equipment and interconnecting cabling INSERT 1 within the subsystem, [are] [is] required to be OPERABLE to support 2

[required] [one] subsystem[s] of the distribution systems [required 1 OPERABLE by LCO 3.8.10, "Distribution Systems - Shutdown."] This ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents

[involving handling recently irradiated fuel]). 1 APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies, 1 provide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core, Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.5-2 Rev. 5.0 2

ITS 3.8.5 1

INSERT 1 one 125 volt battery bank, at least one associated full capacity charger capable of being powered by an OPERABLE diesel generator Insert Page B 3.8.5-2

DC Sources - Shutdown B 3.8.5 BASES APPLICABILITY (continued)

b. Required features needed to mitigate a fuel handling accident

[involving handling recently irradiated fuel (i.e., fuel that has occupied 1 part of a critical reactor core within the previous [X] days)] are available,

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1, A.2, and A.3

REVIEWERS NOTE-----------------------------------

ACTION A is included only when plant-specific implementation of LCO 3.8.5 includes the potential to require both subsystems of the DC System to be OPERABLE. If plant-specific implementation results in 3 LCO 3.8.5 requiring only one subsystem of the DC System to be OPERABLE, then ACTION A is omitted and ACTION B is renumbered as ACTION A.

train required Condition A represents one subsystem with one [or two] battery chargers 2 1 inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.5-3 Rev. 5.0 2

DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued) the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within [12] hours, the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.

REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> plus the time experienced to accomplish the exponential charging 3 current portion of the battery charge profile following the service test (SR 3.8.4.3).

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus, there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown 1 with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within [12] hours (Required Action A.2). 1 Required Action A.2 requires that the battery float current be verified as less than or equal to [2] amps. This indicates that, if the battery had been 1 discharged as the result of the inoperable battery charger, it has now Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.5-4 Rev. 5.0 2

DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued) been fully recharged. If at the expiration of the initial [12] hour period the 1 battery float current is not less than or equal to [2] amps this indicates there may be additional battery problems and the battery must be declared inoperable.

REVIEWERS NOTE-----------------------------------

Any licensee wishing to adopt a Completion Time greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for Required Action A.3 will need to demonstrate that the Completion Time is appropriate for the plant in accordance with the guidance in 3 Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications." Otherwise, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time must be adopted.

Required Action A.3 limits the restoration time for the inoperable battery charger to [72] hours. This action is applicable if an alternate means of 1 restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The [72] hour Completion Time reflects a 1 reasonable time to effect restoration of the qualified battery charger to OPERABLE status.

B.1, B.2.1, B.2.2, and B.2.3

[If two subsystems are required by LCO 3.8.10, the remaining subsystem with DC power available may be capable of supporting sufficient systems 1 to allow continuation of [recently] irradiated fuel movement]. By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend movement of [recently] irradiated fuel assemblies, and 1 operations involving positive reactivity additions) that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6).

Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration.

This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.5-5 Rev. 5.0 2

DC Sources - Shutdown B 3.8.5 BASES ACTIONS (continued)

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power train subsystem[s] and to continue this action until restoration is accomplished 2 1 in order to provide the necessary DC electrical power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires performance of all Surveillances required by SR 3.8.4.1 through SR 3.8.4.3. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

U REFERENCES 1. FSAR, Chapter [6]. 2 1 U 14

2. FSAR, Chapter [15]. 2 1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.5-6 Rev. 5.0 2

JUSTIFICATION FOR DEVIATIONS ITS 3.8.5 BASES, DC SOURCES - SHUTDOWN

1. The Improved Standard Technical Specification (ISTS) contain bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
3. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal Turkey Point Unit 3 and Unit 4 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.5, DC SOURCES - SHUTDOWN There are no specific No Significant Hazards Considerations for this Specification.

Turkey Point Unit 3 and 4 Page 1 of 1

ATTACHMENT 6 ITS 3.8.6, BATTERY PARAMETERS

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS ITS 3.8.6 A01 3/4.8.2 D.C. SOURCES OPERATING Add proposed LCO 3.8.6 A02 LIMITING CONDITION FOR OPERATION 3.8.2.1 The following D.C. electrical sources shall be OPERABLE:*#

a. 125-volt D.C. Battery Bank 3A or spare battery bank D-52 and associated full capacity charger(s)
1) 3A1 powered by motor control center (MCC) 3C with EDG 3A OPERABLE, or
2) 3A2 powered by MCC 4D with EDG 4A and 4B OPERABLE, or
3) 3A1 powered by MCC 3C with EDG 3A OPERABLE and 3A2 powered by MCC 4D with EDG 4A and 4B OPERABLE,
b. 125-volt D.C. Battery Bank 3B or spare battery bank D-52 and associated full capacity charger(s)
1) 3B1 powered by MCC 3B with EDG 3B OPERABLE, or
2) 3B2 powered by MCC 4D with EDG 4A and 4B OPERABLE, or
3) 3B1 powered by MCC 3B with EDG 3B OPERABLE and 3B2 powered by MCC 4D with EDG 4A and 4B OPERABLE,
c. 125-volt D.C. Battery Bank 4A or spare battery bank D-52 and associated full capacity charger(s)
1) 4A1 powered by MCC 4C with EDG 4A OPERABLE, or
2) 4A2 powered by MCC 3D with EDG 3A and 3B OPERABLE, or See ITS
3) 4A1 powered by MCC 4C with EDG 4A OPERABLE and 4A2 powered by 3.8.4 MCC 3D with EDG 3A and 3B OPERABLE,
d. 125-volt D.C. Battery Bank 4B or spare battery bank D-52 and associated full capacity charger(s)
1) 4B1 powered by MCC 4B with EDG 4B OPERABLE, or
2) 4B2 powered by MCC 3D with EDG 3A and 3B OPERABLE, or
3) 4B1 powered by MCC 4B with EDG 4B OPERABLE and 4B2 powered by MCC 3D with EDG 3A and 3B OPERABLE.

Applicability APPLICABILITY: MODES 1, 2, 3, and 4. A02 Add proposed LCO 3.8.6 Applicability ACTION: A03 Add proposed ACTIONS Note

a. With one or more of the required battery chargers OPERABLE but not capable of being powered from its associated OPERABLE diesel generator(s), restore the capability within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units See ITS 3.8.4 simultaneously.

Add proposed ACTIONS A, B, C, D, E, and F L01

  • All battery chargers required to satisfy the LCO shall be powered from separate MCCs.

See ITS 3.8.4

  1. Inoperability of the required EDGs specified in the LCO requirements below does not constitute inoperability of the associated battery chargers or battery banks.

TURKEY POINT - UNITS 3 & 4 3/4 8-13 AMENDMENT NOS. 284 AND 278 Page 1 of 5

ITS ITS 3.8.6 A01 D.C. SOURCES LIMITING CONDITION FOR OPERATION See ITS ACTION: (Continued) 3.8.4

b. With one of the required battery banks inoperable, or with none of the full-capacity chargers associated with a battery bank OPERABLE, restore all battery banks to OPERABLE status and at least one charger associated with each battery bank to OPERABLE status within two hours* or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units simultaneously.

SURVEILLANCE REQUIREMENTS 4.8.2.1 Each 125-volt battery bank and its associated full capacity charger(s) shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying that:

See ITS SR 3.8.6.1 1) The parameters in Table 4.8-2 meet the Category A limits, and 3.8.4 SR 3.8.6.2

2) The total battery terminal voltage is greater than or equal to 129 volts on float charge and the battery charger(s) output voltage is 129 volts, and
3) If two battery chargers are connected to the battery bank, verify each battery charger is supplying a minimum of 10 amperes, or demonstrate that the battery charger supplying less than 10 amperes will accept and supply the D.C. bus load independent of its associated battery charger.
b. In accordance with the Surveillance Frequency Control Program and within 7 days after a battery discharge with battery terminal voltage below 105 volts (108.6 volts for spare battery D-52), or battery overcharge with battery terminal voltage above 143 volts, by verifying that: L02 SR 3.8.6.3
1) The parameters in Table 4.8-2 meet the Category B limits, SR 3.8.6.5 See ITS SR 3.8.6.4 2) The average electrolyte temperature of every sixth cell is above 60°F, and 5.5.14 R2
3) There is no visible corrosion at either terminals or connectors, or verify battery connection resistance is:

Battery Connection Limit (Micro-Ohms) 3B, 4A inter-cell / termination < 29 inter-cell (brace locations) < 30 transition cables < 125 or total battery connections < 1958 Battery Connection Limit (Micro-Ohms) 3A, 4B, D-52 inter-cell / termination < 35 inter-cell (brace locations) < 40 transition cables < 125 or total battery connections < 2463

c. In accordance with the Surveillance Frequency Control Program by verifying that:
1) The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration,
  • Can be extended to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the opposite unit is in MODE 5, 6, or defueled and each of the remaining See ITS 3.8.4 required battery chargers is capable of being powered from its associated diesel generator(s).

TURKEY POINT - UNITS 3 & 4 3/4 8-14 AMENDMENT NOS. 289 AND 283 Page 2 of 5

ITS ITS 3.8.6 A01 D.C. SOURCES See ITS 5.5.14 R2 SURVEILLANCE REOUIREMENTS (Continued)

2) The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material,
3) Each 400 amp battery charger (associated with Battery Banks 3A and 4B) will supply at least 400 amperes at 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and each 300 amp battery charger (associated with Battery Banks 3B and 4A) will supply at least 300 amperes at 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and See ITS
4) Battery Connection resistance is: 3.8.4 Battery Connection Limit (Micro-Ohms) 3B, 4A inter-cell / termination < 29 See ITS inter-cell (brace locations) < 30 5.5.14 R2 transition cables < 125 or total battery connections < 1958 Battery Connection Limit (Micro-Ohms) 3A, 4B, D-52 inter-cell / termination < 35 inter-cell (brace locations) < 40 transition cables < 125 or See ITS total battery connections < 2463 3.8.4
d. In accordance with the Surveillance Frequency Control Program, during shutdown**, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.

Add proposed SR 3.8.6.6 Note A04 SR 3.8.6.6, e. At least once per 12 months, during shutdown**, by giving performance discharge tests of second Frequency battery capacity to any battery that shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% [7% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of rated capacity from its LA01 average on previous performance tests, or is below 90% [93% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturers rating.

Add proposed SR 3.8.6.6 Note A04 SR 3.8.6.6, first f. In accordance with the Surveillance Frequency Control Program, during shutdown**, by verifying Frequency that the battery capacity is at least 80% [87% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturers rating when subjected to a performance discharge test.

Once per 60-month interval this performance discharge test may be performed in lieu of the battery service test required by Specification 4.8.2.1.d.

See ITS 3.8.4 Add proposed SR 3.8.6.6 third Frequency L03 Add proposed SR 3.8.6.6 Note A04 SR 3.8.6.6 **Except that the spare battery bank D-52, and any other battery out of service when spare battery bank D-52 is Note in service may be tested with simulated loads during operation.

TURKEY POINT - UNITS 3 & 4 3/4 8-15 AMENDMENT NOS. 263 AND 258 Page 3 of 5

ITS ITS 3.8.6 A01 TABLE 4.8-2 BATTERY SURVEILLANCE REQUIREMENTS L01 CATEGORY A(1) CATEGORY B(2)

L04 PARAMETER LIMITS FOR EACH LIMITS FOR EACH ALLOWABLE(3)

DESIGNATED PILOT CONNECTED CELL VALUE FOR EACH L05 CELL CONNECTED CELL SR 3.8.6.3 Electrolyte >Minimum level >Minimum level Above top of LA02 Level indication mark, indication mark, plates, and < 1/4 above and < 1/4 above and not maximum level maximum level overflowing L06 indication mark indication mark Greater than or equal to the minimum established design limits SR 3.8.6.2, Float Voltage 2.13 volts 2.13 volts(6) 2.07 volts See ITS SR 3.8.6.5 2.07 5.5.14 R2 Not more than SR 3.8.6.1 0.020 below the Specific average of all Gravity (4) 1.200(5) 1.195 connected cells L07 Average of all Average of all Connected cells connected cells

> 1.205 1.195(5)

TABLE NOTATIONS (1) For any Category A parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> all the Category B measurements are taken and found to be within their allowable values, and provided all Category A and B parameter(s) are restored to within limits within the next 6 days.

L01 (2) For any Category B parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that the Category B parameters are within their allowable values and provided the Category B parameter(s) are restored to within limits within 7 days.

(3) Any Category B parameter not within its allowable value indicates an inoperable battery.

(4) Corrected for electrolyte temperature and level. L07 SR 3.8.6.1 (5) Or battery charging current is less than 2 amps when on charge.

See ITS (6) Corrected for average electrolyte temperature. 5.5.14 R2 TURKEY POINT - UNITS 3 & 4 3/4 8-16 AMENDMENT NOS. 138 AND 133 Page 4 of 5

ITS ITS 3.8.6 A01 D.C. SOURCES SHUTDOWN LIMITING CONDITION FOR OPERATION Add proposed LCO 3.8.6 A02 3.8.2.2 As a minimum, three 125 volt battery banks, each with at least one associated full capacity charger See ITS 3.8.5 capable of being powered by an OPERABLE diesel generator, shall be OPERABLE.

APPLICABILITY: MODES 5* and 6*. A02 Add proposed LCO 3.8.6 Applicability ACTION:

Add proposed ACTIONS Note A03 With one or more of the required 125 volt battery banks or required associated full-capacity chargers inoperable or not capable of being powered from an OPERABLE diesel generator, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel; initiate corrective action to restore the required battery banks and associated full-capacity chargers to OPERABLE status as soon as possible, and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the Reactor Coolant System through at least a 2.2 square inch vent.

Add proposed ACTIONS A, B, C, D, E, and F See ITS 3.8.5 SURVEILLANCE REQUIREMENTS L01 4.8.2.2 The above required 125 volt battery banks and associated full-capacity chargers shall be demonstrated OPERABLE in accordance with Specification 4.8.2.1.

See ITS 3.8.5

  • CAUTION - If the opposite unit is in MODES 1, 2, 3 or 4, see the corresponding Limiting Condition for Operation 3.8.2.1.

TURKEY POINT - UNITS 3 & 4 3/4 8-17 AMENDMENT NOS. 138 AND 133 Page 5 of 5

DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.2.1 is applicable during MODES 1, 2, 3, and 4. CTS 3.8.2.2 is applicable during MODES 5 and 6. ITS Limiting Condition for Operation (LCO) 3.8.6 requires the Battery parameters for the 125 VDC electrical power R2 subsystem to be within limits when the associated DC electrical power trains are required to be OPERABLE. This changes the CTS by replacing the actual MODES with the phrase "When the associated DC electrical power trains are required to be OPERABLE."

The purpose of ITS 3.8.6 is to provide battery parameter requirements for safety related batteries. This change combines CTS 3.8.2.1 and CTS 3.8.2.2 requirements for the 125 VDC battery parameters into one Specification. There are no technical changes because of this change since it converts the requirements into the format of the ITS. The proposed LCO states that the required battery's parameters shall be within limits. The proposed Applicability ensures the battery parameter requirements are met when the associated battery is required to be OPERABLE. Any technical changes to the battery parameters are discussed in a Discussion of Change (DOC) specifically associated with that change. Any changes to the LCO and Applicability of the 125 VDC batteries are discussed in the DOCs for ITS 3.8.4 and ITS 3.8.5. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 3.8.2.1 contains a table that describes battery degradation levels where separate actions are taken for each battery depending on the level of degradation. ITS 3.8.6 ACTIONS Note states that separate condition entry is allowed for each battery. This changes the CTS by explicitly stating the intent of CTS.

The purpose of ITS 3.8.6 is to provide battery parameter requirements for safety related batteries. As in CTS, exceeding the battery parameter limits in ITS 3.8.6 is indicative of a degradation of battery capacity but the battery may still be capable of performing its specified safety function (i.e., OPERABLE).

Compliance with the Required Actions within the associated Completion Times provides assurance that there is still sufficient battery capacity to perform its specified safety function without considering the battery inoperable. As in CTS, if the battery parameter condition degrades such that the parameter is outside the Conditions allowed or the Required Actions are not accomplished within the associated Completion Time the battery is considered inoperable and the Turkey Point Unit 3 and Unit 4 Page 1 of 9

DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS appropriate Condition(s) entered for the equipment the battery supports. This change is designated as administrative because it does not result in technical changes to the CTS.

A04 CTS 4.8.2.1.e and CTS 4.8.2.1.f require a battery discharge test for the batteries.

The Surveillance specifies that the testing be performed during shutdown conditions and is modified by footnote **. Footnote ** provides an exception to the "during shutdown" condition stating that except for the spare battery bank D-52, and any other battery out of service when spare battery bank D-52 is in service may be tested with simulated loads during operation. ITS Surveillance Requirement (SR) 3.8.6.6 requires a similar verification of battery capacity and is modified by a similar Note. ITS SR 3.8.6.6, Note states that for the battery discharge test the Surveillance shall not be performed on in-service batteries in MODE 1, 2, 3, or 4; however, credit may be taken for unplanned events that satisfy this SR. This changes the CTS requirement by specifying conditions for when the associated batteries are tested.

The purpose of CTS 4.8.2.1.e and CTS 4.8.2.1.f is to verify the OPERABILITY of the DC Batteries. The addition of the Note limiting the conditions under which the Surveillance can be performed is acceptable because performance of the Surveillance on in-service batteries could cause perturbations to the electrical distribution system. Restricting performance of the Surveillance to a battery not in-service during MODES 1, 2, 3, and 4 minimizes challenges to continued steady state operation and, as a result, the units safety systems. In addition, providing a statement that credit may be taken if the Surveillance is performed during unplanned event does not change the CTS because credit can be taken if it can be shown the unplanned event satisfied the Surveillance. This change is designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.1.e states, in part, that degradation is indicated when the battery capacity drops more than 10% [7% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of rated capacity from its average on previous performance tests, or is below 90% [93% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturers rating. ITS 3.8.6 does not include this description of degradation. This changes the CTS by removing the description of what is indicative of battery degradation.

Turkey Point Unit 3 and Unit 4 Page 2 of 9

DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to perform a performance discharge test of battery capacity to any battery that shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of service life expected for the application that continues to assure protection of public health and safety. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.1.b.1 requires verifying that the parameters in Table 4.8-2 meet the Category B. CTS Table 4.8-2 includes the electrolyte level Category B limits for each connected cell that must be verified of that the battery electrolyte level is > the minimum level indication mark, and 1/4 inch above maximum level indication mark in accordance with the Surveillance Frequency Control Program (SFCP). ITS SR 3.8.6.3 requires a similar Surveillance and specifies the acceptance criteria as "greater than or equal to the minimum established design limits." The minimum established design limits for battery electrolyte level will be placed in the ITS Bases. This changes the CTS by moving the specified limits for this SR to the ITS Bases.

The removal of these details related to SR limits from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This Category B value of CTS Table 4.8-2 represent R2 appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery life. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.

This program provides for the evaluation of changes to ensure the Bases are properly controlled. Furthermore, the battery and its preventive maintenance and monitoring program are under the regulatory requirements of 10 CFR 50.65.

This relocation will continue to assure that the battery is maintained at current levels of performance, and that operators appropriately focus on monitoring the battery parameters for degradation. This change is designated as a less restrictive removal of detail change because the Surveillance limits are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.2.1 and CTS 3.8.2.2 provide ACTIONS and associated Completion Times for when a 125 V battery is inoperable due to battery parameters not within limits. In addition, CTS Turkey Point Unit 3 and Unit 4 Page 3 of 9

DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS Table 4.8-2 provides in the form of Notes (1), (2), and (3), ACTIONS and R2 associated Completions Times when Category A or Category B parameter limits or allowable values are exceeded. In lieu of these current Actions under these conditions, ITS 3.8.6 ACTIONS provide compensatory Required Actions and associated Completion Times when battery parameters are not within limits. This changes the CTS by replacing the current ACTIONS with new compensatory ACTIONS for battery parameters not within limits.

The purpose of CTS 3.8.2.1 and CTS 3.8.2.2 ACTIONS are to provide a finite R2 period for continued operation when a battery is inoperable due to battery parameters not within limits. ITS 3.8.6 ACTIONS also allow a certain amount of time to restore battery parameters to within limits before declaring the associated battery inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to correct degraded conditions. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features including the capacity and capability of remaining systems or features, time for repairs or replacement, and the low probability of a Design Basis Accident (DBA) occurring during the Completion Time. ACTIONS have been added to allow a short period to restore parameters to within limits. ITS 3.8.6, ACTION A, covers the condition of one or more batteries with one or more battery cells float voltage less than the specified limit and requires the performance of SR 3.8.4.1 (Verify battery terminal voltage is greater than or equal to the minimum established float voltage) within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the performance of SR 3.8.6.1 (Verify each battery float current is 2 amps) within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and restoration of the affected cell voltage to within limits within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.8.6, ACTION B, covers the condition of one or more batteries with float current not within the specified limit and requires the performance of SR 3.8.4.1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and restoration of the battery float current to within limits within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.8.6, ACTION C, covers the condition of one or more batteries with one or more cells electrolyte level less than minimum established design limits and requires the restoration of electrolyte level to above top of plates within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, verification that there is no evidence of leakage within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and restoration of electrolyte level to greater than or equal to the minimum established design limits within 31 days. ITS 3.8.6, ACTION C Note, requires Required Action C.2 to be completed if electrolyte level was below the top of plates. Because with electrolyte level below the top of the plates there is a potential for dryout and plate degradation, this Note requires verification of no evidence of leakage even if the level is increased above the top of the plates allowing the Condition to be exited. ITS 3.8.6, Required Action C.1 Note, states that Required Actions C.1 and C.2 are only applicable if electrolyte level was below the top of the plates allowing 31 days to restore electrolyte level to greater than or equal to the minimum established design level. ITS 3.8.6, ACTION D, covers the condition of one or more batteries with pilot cell electrolyte temperature less than the minimum established design limits and requires the restoration of battery pilot cell temperature to greater than or equal to minimum established design limits within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.8.6, ACTION E, covers the condition of one or more batteries in redundant trains with battery parameters not within limits and requires restoration of the battery parameters for two batteries to Turkey Point Unit 3 and Unit 4 Page 4 of 9

DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS within limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ITS 3.8.6, ACTION F, covers the conditions when a Required Action and associated Completion Time of any of the above ACTIONS cannot be met, if one or more batteries with one or more battery cells float voltage and float current are not within limits, or if battery parameters are not within limits for any reason other than Condition A, B, C, D, or E; and requires the immediate declaration that the associated battery is inoperable. The allowances are considered acceptable because only a short period is allowed with battery parameters not within limits. In addition, when one or more batteries in redundant trains have battery parameters not within limit, only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is allowed to restore at least two battery's parameters before declaring the battery(ies) inoperable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L02 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.2.1.b requires the performance of several Surveillances within 7 days after a battery discharge (battery terminal voltage below 105 volts (108.6 volts for spare battery D-52), or battery overcharge with battery terminal voltage above 143 volts. ITS 3.8.6 does not require these Surveillances to be performed after a battery discharge or overcharge. This changes the CTS by not including a specific Surveillance Requirement to perform these tests after a discharge or overcharge.

The purpose of the CTS 4.8.2.1.b Frequency is to ensure the batteries remain OPERABLE after a severe battery discharge or overcharge. This change is acceptable because other proposed Surveillance Requirements continue to ensure an acceptable level of equipment reliability. ITS SR 3.8.6.1 requires verification that each battery float current is 2 amps at a periodic frequency in R2 accordance with the Surveillance Frequency Control Program. The float current requirements are based on the float current indicative of a charged battery.

Therefore, this Surveillance will detect a discharge condition of the battery. In addition, ITS 5.5.14, "Battery Monitoring and Maintenance Program," requires a program for battery maintenance based on the recommendations of IEEE 450-2010. The requirement to perform these battery preventative maintenance activities are consistent with IEEE 450-2010, and as such, will be maintained in the plant procedures implementing ITS 5.5.14. This change is designated as R2 less restrictive because Surveillances will be performed less frequently under ITS than under CTS.

L03 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.2.1.e requires an increased Frequency (Annually) from that in CTS 4.8.2.1.f, in accordance with the SFCP (60 months), for battery performance tests if the battery shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of its expected service life. ITS SR 3.8.6.6 provides two Frequencies when a battery has reached 85% of its expected service life based on whether the battery's remaining capacity is less than 100% or not. If the battery's remaining capacity is less than 100% of the manufactures rating the required discharge test is performed every 12 months (annually). If the battery's remaining capacity is greater than or equal to 100% of the manufactures rating, then the required discharge test is performed every 24 months. This changes the CTS by relaxing the Frequency of required discharge tests when the battery Turkey Point Unit 3 and Unit 4 Page 5 of 9

DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of its expected service life.

The purpose of CTS 4.8.2.1.e is to verify the battery capacity is acceptable on R2 batteries that show signs of degradation or have reached 85% of the service life.

ITS 3.8.6.6 provides an alternative Frequency if the battery that has reached 85% of its service life but has not shown signs of degradation and has a capacity of greater than or equal to 100% of the manufactures rating. This relaxed frequency is acceptable because the battery has not shown signs of degradation, retains greater than or equal to the manufacturers rated capacity, and is being tested at a more frequent periodicity than a battery that has not reached 85%

[75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the service life expected. Also, IEEE 450-2010 states that if the battery has reached 85% of service life, delivers a capacity of 100% or greater of the manufacturers rated capacity, and has shown no signs of degradation, performance testing at two-year intervals is acceptable until the battery shows signs of degradation.

This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.

L04 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.1.a.1 requires verifying the battery parameters in Table 4.8-2 meet Category A limits In R2 accordance with the SFCP. CTS Table 4.8-2 Category A contains the parameter

'Electrolyte Level' with the limit for each designated pilot cell set at "> Minimum level indication mark, and 1/4" above maximum level indication mark."

CTS 4.8.2.1.b.1 requires verifying the parameters in Table 4.8-2 meet Category B limits in accordance with the SFCP. CTS Table 4.8-2, Category B, R2 contains the parameter 'Electrolyte Level' with the limit for each connected cell set at "> Minimum level indication mark, and 1/4" above maximum level indication mark." In addition, the Category B electrolyte level Allowable Value for each connected cell (which includes the pilot cells) is above the top of plates, and not overflowing. ITS SR 3.8.6.3 requires verifying each battery connected cell electrolyte level is greater than or equal to minimum established design limits in accordance with the SFCP. This changes the CTS by deleting the requirement to verify the pilot cells electrolyte level is within limits in accordance with the SFCP.

The purpose of CTS Category A limit on pilot cell electrolyte level and its related Frequency is to represent appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery life. The definition of LCO presented in 10 CFR 50.36 states that LCOs are "the lowest functional capability or performance levels of equipment required for safe operation of the facility." As such, the Category A value for cell electrolyte level does not reflect the 10 CFR 50.36 criteria for LCOs. ITS 5.5.14, "Battery Monitoring and Maintenance Program," requires a program providing controls for battery restoration and maintenance that shall be in accordance with IEEE 450-2010 as endorsed by Regulatory Guide (RG) 1.129, "Maintenance, Testing, and Replacement of Vented Lead-Acid Storage Batteries for Nuclear Power Plants," Revision 3, with exceptions and other provisions. IEEE 450-2010 contains, in part, guidance on monitoring electrolyte level with the intention of providing recommended maintenance, test schedules, and testing procedures Turkey Point Unit 3 and Unit 4 Page 6 of 9

DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS that can be used to optimize the life and performance of permanently installed, vented lead-acid storage batteries used for standby power applications. These values and actions associated with restoration are being replaced by a licensee-controlled program, required and described in Technical Specification Section 5.5, "Programs and Manuals," and titled the "Battery Monitoring and Maintenance Program." This provides adequate assurance that necessary battery parameter values will continue to be controlled and actions will be implemented if the battery parameter values are not met. Furthermore, the battery and its preventive maintenance and monitoring program are under the regulatory requirements of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L05 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.1.b.1 requires verifying the battery parameters in Table 4.8-2 meet Category B limits in R2 accordance with the SFCP. CTS Table 4.8-2, Category B, contains the parameter 'Electrolyte Level' with an Allowable Value for each connected cell of "Above top of plates, and not overflowing." In addition, Note (3) states that with any Category B parameter not within its Allowable Value indicates an inoperable battery. ITS SR 3.8.6.3 requires verifying each battery connected cell electrolyte level is greater or equal to minimum established design limits in accordance with the SFCP. ITS 3.8.6, Required Action C.1, requires restoration of battery's electrolyte level to above the top of the plates within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or Condition F is entered with a Required Action to declare the associated battery inoperable immediately. This changes the CTS by relaxing the requirement of immediately declaring the battery inoperable and allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to restore the battery parameter to within limits before declaring the battery inoperable.

The purpose of CTS Category B Allowable Value on each connected cell for electrolyte level and its related Frequency is to ensure that the plates suffer no physical damage and maintain adequate electron transfer capability to ensure the battery can perform its specified safety function and maintain a margin of safety. Electrolyte level cannot decrease to below the top of the plates or be overflowing unless it has exceeded the limits prescribed in ITS SR 3.8.6.3. If battery electrolyte level is found outside the minimum established design limits ITS 3.8.6, Condition C, is entered with Required Action C.1 requiring restoring electrolyte level to above the top of the plates within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or declaring the battery inoperable. With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. ITS 5.5.14, Battery Monitoring and Maintenance Program," requires a program providing controls for battery restoration and maintenance that shall be in accordance with IEEE 450-2010 as endorsed by RG 1.129, Revision 3 and other provisions. IEEE 450-2010 R2 contains, in part, guidance on monitoring electrolyte level with the intention of providing recommended maintenance, test schedules, and testing procedures that can be used to optimize the life and performance of permanently installed, vented lead-acid storage batteries used for standby power applications. New Required Actions C.1 and C.2 restore the electrolyte level and ensure that the cause of the loss of electrolyte level is not due to a leak in the battery cell jar.

These changes, with the additional requirements in the Battery Monitoring and Turkey Point Unit 3 and Unit 4 Page 7 of 9

DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS Maintenance Program, are adequate to ensure that minimum electrolyte levels are maintained. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.

L06 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)

CTS 4.8.2.1.a.1 requires verifying the battery parameters in Table 4.8-2 meet R2 Category A limits in accordance with the SFCP. CTS Table 4.8-2, Category A, contains the parameter 'Float Voltage' with a limit for each designated pilot cell of

" 2.13 volts." ITS SR 3.8.6.2 requires the verification that each pilot cell voltage is 2.07 V. ITS 3.8.6, ACTION A, addresses the condition in which one or more batteries with one or more battery cells float voltage less than 2.07 V. Once ACTION A has been entered, the battery cell is considered degraded and the Required Actions are to perform SR 3.8.4.1 and SR 3.8.6.1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This changes the CTS by reducing the acceptance criteria for pilot cell voltage limits from 2.13 V to 2.07 V.

The purpose of the proposed Surveillance limit in ITS SR 3.8.6.2 is to ensure the cell voltages are greater than or equal to the short-term absolute minimum voltage. A cell voltage of 2.07 V or below under float conditions may indicate internal cell problems while prolonged operation of cells below 2.13 V has the potential to reduce the life expectancy of cells. This changes the CTS by R2 reducing the acceptance criteria for pilot cell voltage limits from 2.13 V to 2.07 V. At this lower voltage, the cell can still perform its function. The battery is considered OPERABLE when the battery voltage on float is greater than or equal to the minimum establish voltage of ITS SR 3.8.4.1. This change is acceptable since ITS 5.5.14, "Battery Monitoring and Maintenance Program," has been added and requires actions to be taken to restore battery cells with float voltage < 2.13 V. This program will help ensure the cell voltage will not approach the limit of 2.07 V and that the minimum established voltage of ITS SR 3.8.4.1 is maintained. This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.

L07 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.1.a.1 requires the verification that the pilot cell specific gravity is within the Category A limits of Table 4.8-2, as modified by footnote (4) and CTS 4.8.2.1.b.1 requires the verification that the connected cell specific gravity is within the Category B limits of Table 4.8-2, as modified by footnote (4). As indicated in CTS Table 4.8-2 (footnote (4)), the specific gravity limit must be corrected for electrolyte temperature and level. ITS 3.8.6 does not include these Surveillances. This changes the CTS by deleting the Surveillances to verify battery cell specific gravity.

The purpose of CTS 4.8.2.1.a.1, and 4.8.2.1.b.1 is to ensure the state of charge of each battery cell. This change is acceptable because the deleted SRs are not necessary to verify that the equipment used to meet the LCO can perform its required functions. Appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. While the specified Surveillances have been deleted, the alternative Surveillances of CTS Table 4.8-2, footnote (5) to verify battery float current is < 2 amps is retained in ITS as SR 3.8.6.1, with Turkey Point Unit 3 and Unit 4 Page 8 of 9

DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS modifications to the acceptance criteria to reflect the information provided by the battery manufacturer. IEEE 450-2010 states that the most accurate indicator of return to full charge is a stabilized charging or float current. Specific gravity readings may not be accurate when the battery is on charge following a discharge. Therefore, ITS SR 3.8.6.1 gives a better indication of the overall battery condition. This change is designated as less restrictive because Surveillances which are required in CTS will not be required in ITS.

Turkey Point Unit 3 and Unit 4 Page 9 of 9

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS Battery Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters the 125 VDC DOC A02 LCO 3.8.6 Battery parameters for Train A and Train B batteries electrical power 1 subsystem shall be within limits.

trains DOC A02 APPLICABILITY: When associated DC electrical power subsystems are required to be 1 OPERABLE.

ACTIONS

NOTE-----------------------------------------------------------

DOC A03 Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME or more required DOC L01 A. One [or two] batter[y][ies A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 2

on one subsystem] with one or more battery cells AND float voltage < [2.07] V. 2 A.2 Perform SR 3.8.6.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> AND A.3 Restore affected cell 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> voltage [2.07] V. 2 or more required DOC L01 B. One [or two] batter[y][ies B.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on one subsystem] with 2 float current > [2] amps. AND B.2 Restore battery float current [12] hours 2

to [2] amps.

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.6-1 Rev. 5.0 1

CTS Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 C. -----------NOTE------------- -------------------NOTE--------------------

Required Action C.2 Required Actions C.1 and C.2 are shall be completed if only applicable if electrolyte level electrolyte level was was below the top of plates.

below the top of plates. ------------------------------------------------

or more required C.1 Restore electrolyte level to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> One [or two] batter[y][ies above top of plates.

on one subsystem] with 2 one or more cells AND electrolyte level less than minimum C.2 Verify no evidence of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> established design leakage.

limits.

AND C.3 Restore electrolyte level to 31 days greater than or equal to minimum established design limits.

or more required DOC L01 D. One [or two] batter[y][ies D.1 Restore battery pilot cell 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2 on one subsystem] with temperature to greater than pilot cell electrolyte or equal to minimum temperature less than established design limits.

minimum established design limits.

required DOC L01 E. One or more batteries in E.1 Restore battery parameters 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> redundant subsystems for batteries in one trains 1 with battery parameters subsystem to within limits.

two trains not within limits.

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.6-2 Rev. 5.0 1

CTS Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 F. Required Action and F.1 Declare associated battery Immediately associated Completion inoperable.

Time of Condition A, B, C, D, or E not met.

OR or more required One [or two] batter[y][ies 2 on one subsystem] with one or more battery cells float voltage < [2.07] V 2 and float current

> [2] amps. 2 INSERT 1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.2.1.a.1) SR 3.8.6.1 -------------------------------NOTE------------------------------

Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.

required Verify each battery float current is [2] amps. [ 7 days 2

OR In accordance with the Surveillance Frequency Control Program ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.6-3 Rev. 5.0 1

3 INSERT 1 DOC L01 OR Battery parameters not within limits for any reason other than Condition A, B, C, D, or E.

Insert Page 3.8.6-3

CTS Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.2.1.a.1) SR 3.8.6.2 Verify each battery pilot cell float voltage is [ 31 days

[2.07] V. 2 OR In accordance with the Surveillance Frequency Control Program ] 2 4.8.2.1.b.1) SR 3.8.6.3 Verify each battery connected cell electrolyte level is [ 31 days greater than or equal to minimum established 2 design limits. OR In accordance with the Surveillance Frequency Control Program ] 2 4.8.2.1.b.2) SR 3.8.6.4 Verify each battery pilot cell temperature is greater [ 31 days than or equal to minimum established design limits. 2 OR In accordance with the Surveillance Frequency Control Program ] 2 4.8.2.1.b.1) SR 3.8.6.5 Verify each battery connected cell float voltage is [ 92 days

[2.07] V. 2 OR In accordance with the Surveillance Frequency Control Program ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.6-4 Rev. 5.0 1

CTS Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.8.2.1.e, on in-service batteries 4.8.2.1.f SR 3.8.6.6 -------------------------------NOTE------------------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish 4 OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

INSERT 2 Verify battery capacity is [80%] of the [ 60 months manufacturer's rating when subjected to a 2 performance discharge test or a modified OR performance discharge test.

In accordance with the Surveillance Frequency Control Program ] 2 AND 12 months when battery shows degradation, or INSERT 3 has reached

[85]% of the 2 expected life with capacity < 100%

of manufacturer's rating AND 24 months when battery has INSERT 3 reached [85]% of 2 DOC L03 the expected life with capacity 100% of manufacturer's rating Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.6-5 Rev. 5.0 1

2 INSERT 2 80% (87% for Batteries 4B and D52 (Spare) when used in place of Battery 4B) 2 INSERT 3 85% (75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B)

Insert Page 3.8.6-5

JUSTIFICATION FOR DEVIATIONS ITS 3.8.6, BATTERY PARAMETERS

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. ISTS Surveillance Requirement (SR) 3.8.6.6 requires a battery performance discharge or modified performance discharge test to be performed and provides acceptance criteria. However, no ACTION is provided in the ISTS 3.8.6 ACTIONS for when this SR is not met. Therefore, in the ISTS, Limiting Condition for Operation (LCO) 3.0.3 would be entered. To preclude an LCO 3.0.3 entry, ISTS 3.8.6 Condition F has been modified to cover other reasons the battery parameters may not be met other than the conditions listed, e.g., when SR 3.8.6.6 is not met.

ITS 3.8.6 ACTION F will require the associated battery to be declared inoperable.

This is also consistent with the current Technical Specification requirements.

4. The Note modifying ISTS SR 3.8.6.6 has be changed to reflect that no portion of the battery performance discharge or modified performance discharge test can be performed on an in-service battery in MODES 1, 2, 3, or 4 without making the battery inoperable. This test is normally performed by removing the battery from service and placing the spare vital battery in-service. Furthermore, the test is not performed in steps, where only part of the test can be performed.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Battery Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery Parameters BASES BACKGROUND This LCO delineates the limits on battery float current as well as electrolyte temperature, level, and float voltage for the DC power subsystem batteries. A discussion of these batteries and their OPERABILITY requirements is provided in the Bases for LCO 3.8.4, "DC Sources - Operating," and LCO 3.8.5, "DC Sources - Shutdown." In Battery Monitoring and addition to the limitations of this Specification, the [licensee controlled 1

Maintenance Program program] also implements a program specified in Specification 5.5.16 for 4 monitoring various battery parameters. 14 The battery cells are of flooded lead acid construction with a nominal specific gravity of [1.215]. This specific gravity corresponds to an open 124 circuit battery voltage of approximately 120 V for [58] cell battery (i.e., cell 1 voltage of [2.065] volts per cell (Vpc)). The open circuit voltage is the 60 voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage [2.065] Vpc, the battery cell will 2 maintain its capacity for [30] days without further charging per manufacturer's instructions. Optimal long term performance however, is 2.17 obtained by maintaining a float voltage [2.20 to 2.25] Vpc. This provides 1 adequate over-potential which limits the formation of lead sulfate and self discharge. The nominal float voltage of [2.22] Vpc corresponds to a total float voltage output of [128.8] V for a [58] cell battery as discussed in the 2 FSAR, Chapter [8] (Ref. 2).

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient U

SAFETY analyses in the FSAR, Chapter [6] (Ref. 3) and Chapter [15] (Ref. 4), 14 2 1 ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical emergency diesel generators power for the DGs, emergency auxiliaries, and control and switching 3 during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial 3 assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining at least one train subsystem of DC sources OPERABLE during accident conditions, in the 3 event of:

a. An assumed loss of all offsite AC power or all onsite AC power and 3
b. A worst-case single failure.

Battery parameters satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-1 Rev. 5.0 3

Battery Parameters B 3.8.6 BASES LCO Battery parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Battery parameter limits are conservatively established, allowing continued DC electrical system function even with limits not met. Additional preventative maintenance, testing, and Battery Monitoring and monitoring performed in accordance with the [licensee controlled 1 14 Maintenance Program program] is conducted as specified in Specification 5.5.16. 4 APPLICABILITY The battery parameters are required solely for the support of the associated DC electrical power subsystems. Therefore, battery 3 parameter limits are only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussion in Bases for LCO 3.8.4 and LCO 3.8.5.

ACTIONS A.1, A.2, and A.3 With one or more cells in one or more batteries in one subsystem 4

< [2.07] V, the battery cell is degraded. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> verification of the 1 required battery charger OPERABILITY is made by monitoring the battery terminal voltage (SR 3.8.4.1) and of the overall battery state of charge by monitoring the battery float charge current (SR 3.8.6.1). This assures that there is still sufficient battery capacity to perform the intended function.

Therefore, the affected battery is not required to be considered inoperable solely as a result of one or more cells in one or more batteries < [2.07] V, 1 and continued operation is permitted for a limited period up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Since the Required Actions only specify "perform," a failure of SR 3.8.4.1 or SR 3.8.6.1 acceptance criteria does not result in this Required Action not met. However, if one of the SRs is failed the appropriate Condition(s),

depending on the cause of the failures, is entered. If SR 3.8.6.1 is failed then there is not assurance that there is still sufficient battery capacity to perform the intended function and the battery must be declared inoperable immediately.

B.1 and B.2 One or more batteries in one subsystem with float current > [2] amps 4 1 indicates that a partial discharge of the battery capacity has occurred.

This may be due to a temporary loss of a battery charger or possibly due to one or more battery cells in a low voltage condition reflecting some loss of capacity. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage. If the terminal voltage is found to be less than the minimum established float voltage there are two possibilities, the battery charger is inoperable or is Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-2 Rev. 5.0 3

Battery Parameters B 3.8.6 BASES ACTIONS (continued) operating in the current limit mode. Condition A addresses charger inoperability. If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that is an indication that the battery has been substantially discharged and likely cannot perform its required design functions. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within

[12] hours (Required Action B.2). The battery must therefore be declared 1 inoperable.

If the float voltage is found to be satisfactory but there are one or more battery cells with float voltage less than [2.07] V, the associated "OR" 1 statement in Condition F is applicable and the battery must be declared inoperable immediately. If float voltage is satisfactory and there are no cells less than [2.07] V there is good assurance that, within [12] hours, the 1 battery will be restored to its fully charged condition (Required Action B.2) from any discharge that might have occurred due to a temporary loss of the battery charger.

REVIEWERS NOTE-----------------------------------

A plant that cannot meet the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time due to an inherent battery charging characteristic can propose an alternate time equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> plus the time experienced to accomplish the exponential charging 5 current portion of the battery charge profile following the service test (SR 3.8.4.3).

A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within [12] hours, avoiding a premature shutdown with its own attendant 1 risk.

If the condition is due to one or more cells in a low voltage condition but still greater than [2.07] V and float voltage is found to be satisfactory, this 1 is not indication of a substantially discharged battery and [12] hours is a reasonable time prior to declaring the battery inoperable.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-3 Rev. 5.0 3

Battery Parameters B 3.8.6 BASES ACTIONS (continued)

Since Required Action B.1 only specifies "perform," a failure of SR 3.8.4.1 acceptance criteria does not result in the Required Action not met.

However, if SR 3.8.4.1 is failed, the appropriate Condition(s), depending on the cause of the failure, is entered.

C.1, C.2, and C.3 With one or more batteries in one subsystem with one or more cells 4 electrolyte level above the top of the plates, but below the minimum established design limits, the battery still retains sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of electrolyte level not met. Within 31 days the minimum established design limits for electrolyte level must be re-established.

With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. Required Actions C.1 and C.2 address this 14 potential (as well as provisions in Specification 5.5.16, Battery Monitoring 4 and Maintenance Program). They are modified by a Note that indicates they are only applicable if electrolyte level is below the top of the plates.

Within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> level is required to be restored to above the top of the plates. The Required Action C.2 requirement to verify that there is no 14 leakage by visual inspection and the Specification 5.5.16.b item to initiate 4 action to equalize and test in accordance with manufacturer's recommendation are taken from IEEE Standard 450. They are performed following the restoration of the electrolyte level to above the top of the plates. Based on the results of the manufacturer's recommended testing the batter[y][ies] may have to be declared inoperable and the affected 1 cell[s] replaced.

D.1 With one or more batteries in one subsystem with pilot cell temperature 4 less than the minimum established design limits, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed to restore the temperature to within limits. A low electrolyte temperature limits the current and power available. Since the battery is sized with margin, while battery capacity is degraded, sufficient capacity exists to perform the intended function and the affected battery is not required to be considered inoperable solely as a result of the pilot cell temperature not met.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-4 Rev. 5.0 3

Battery Parameters B 3.8.6 BASES ACTIONS (continued)

E.1 trains With one or more batteries in redundant subsystems with battery 4 parameters not within limits there is not sufficient assurance that battery capacity has not been affected to the degree that the batteries can still perform their required function, given that redundant batteries are involved. With redundant batteries involved this potential could result in a total loss of function on multiple systems that rely upon the batteries. The longer Completion Times specified for battery parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one subsystem 4 train within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

F.1 With one or more batteries with any battery parameter outside the allowances of the Required Actions for Condition A, B, C, D, or E, sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding battery must be declared inoperable.

Additionally, discovering one or more batteries in one subsystem with one 4 or more battery cells float voltage less than [2.07] V and float current 1

, or failure of greater than [2] amps indicates that the battery capacity may not be 4 SR 3.8.6.6 R2 sufficient to perform the intended functions. The battery must therefore be declared inoperable immediately.

SURVEILLANCE SR 3.8.6.1 REQUIREMENTS Verifying battery float current while on float charge is used to determine the state of charge of the battery. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a charged state.

The float current requirements are based on the float current indicative of a charged battery. Use of float current to determine the state of charge of the battery is consistent with IEEE-450 (Ref. 1). [ The 7 day Frequency is consistent with IEEE-450 (Ref. 1). 1 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-5 Rev. 5.0 3

Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

This SR is modified by a Note that states the float current requirement is not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. When this float voltage is not maintained the Required Actions of LCO 3.8.4 ACTION A are being taken, which provide the necessary and appropriate verifications of the battery condition. Furthermore, the float current limit of [2] amps is established based on the nominal float voltage value and is not directly applicable when this voltage is not maintained.

SR 3.8.6.2 and SR 3.8.6.5 Optimal long term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits 130.2 provided by the battery manufacturer, which corresponds to [130.5] V at 2.17 1 the battery terminals, or [2.25] Vpc. This provides adequate over-potential, which limits the formation of lead sulfate and self discharge, which could eventually render the battery inoperable. Float voltages in this range or less, but greater than [2.07] Vpc, are addressed in 1 14 Specification 5.5.16. SRs 3.8.6.2 and 3.8.6.5 require verification that the 4 cell float voltages are equal to or greater than the short term absolute minimum voltage of [2.07] V. [ The Frequency for cell voltage verification every 31 days for pilot cell and 92 days for each connected cell is consistent with IEEE-450 (Ref. 1). 1 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-6 Rev. 5.0 3

Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.6.3 The limit specified for electrolyte level ensures that the plates suffer no The minimum established design physical damage and maintains adequate electron transfer capability.

limits for battery electrolyte level [ The Frequency of 31 days is consistent with IEEE-450 (Ref. 1).

are greater than the minimum 1 R2 level indication mark and less than 1/4 inch above maximum level OR indication mark.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SR 3.8.6.4 This Surveillance verifies that the pilot cell temperature is greater than or equal to the minimum established design limit (i.e., [40]°F). Pilot cell 60 1 electrolyte temperature is maintained above this temperature to assure the battery can provide the required current and voltage to meet the design requirements. Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. [ The Frequency of 31 days is consistent with IEEE-450 (Ref. 1). 1 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-7 Rev. 5.0 3

Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.6.6 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.6.6; however, only the modified performance discharge test may be used to satisfy the battery service test requirements of SR 3.8.4.3.

A modified discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test.

It may consist of just two rates; for instance the one minute rate for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test, both of which envelope the duty cycle of the service test. Since the ampere-hours removed by a one minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test must remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 1) and IEEE-485 (Ref. 5). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's (87% for Batteries rating. A capacity of 80% shows that the battery rate of deterioration is 3 4B and D52 (Spare) increasing, even if there is ample capacity to meet the load requirements.

when used in place Furthermore, the battery is sized to meet the assumed duty cycle loads of Battery 4B) when the battery design capacity reaches this [80]% limit. 1 3

[ The Surveillance Frequency for this test is normally 60 months. 1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-8 Rev. 5.0 3

Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)

OR 1 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

(75% for Batteries

]

4B and D52 (Spare) when used in place If the battery shows degradation, or if the battery has reached 85% of its 3 of Battery 4B) expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the 3 Surveillance Frequency is only reduced to 24 months for batteries that retain capacity 100% of the manufacturer's ratings. Degradation is indicated, according to IEEE-450 (Ref. 1), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is [10%] below the manufacturer's rating. 1 These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 1).

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. This restriction from normally performing the 1, 2, 3, or 4 Surveillance in MODE 1 or 2 is further amplified to allow portions of the the performance of Surveillance to be performed for the purpose of reestablishing this Surveillance on batteries that are OPERABILITY (e.g., post work testing following corrective maintenance, not in-service. corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients 4 associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment.

Credit may be taken for unplanned events that satisfy this SR.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-9 Rev. 5.0 3

Battery Parameters B 3.8.6 BASES

-2010 3 REFERENCES 1. IEEE-450.

U

2. FSAR, Chapter 8. 3 U
3. FSAR, Chapter [6]. 3 1 U 14
4. FSAR, Chapter [15]. 3 1 1997
5. IEEE-485-[1983], June 1983. 1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-10 Rev. 5.0 3

JUSTIFICATION FOR DEVIATIONS ITS 3.8.6 BASES, BATTERY PARAMETERS

1. The Improved Standard Technical Specification (ISTS) contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis
2. These battery design values have been deleted because this type of information is not necessary to provide sufficient background for this Specification.
3. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
4. Changes have been made to reflect changes made to other Specifications.
5. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.6, BATTERY PARAMETERS There are no specific No Significant Hazards Considerations for this Specification.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

ATTACHMENT 7 ITS 3.8.7, INVERTERS - OPERATING

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS ITS 3.8.7 A01 3/4.8.3 ONSITE POWER DISTRIBUTION OPERATING LIMITING CONDITION FOR OPERATION required inverters shall be OPERABLE A01 LCO 3.8.7 3.8.3.1 The following electrical busses* shall be energized in the specified manner with the tie breakers open See ITS between redundant busses within the unit** and between the busses of Units 3 and 4. 3.8.9

a. One train of A.C. Busses consisting of:
1) 4160-Volt Bus A,
2) 480-Volt Load Center Busses A, C and H***, and
3) 480-Volt Motor Control Center Busses A (Unit 4 only),C and D***,
b. One train of A.C. Busses consisting of:
1) 4160-Volt Bus B
2) 480-Volt Load Center Busses B, D and H***, and See ITS
3) 480-Volt Motor Control Center Busses B and D*** 3.8.9
c. One opposite unit train of AC busses consisting of either:
1) 4160-Volt Bus A, 480-Volt Load Center Busses A, C and H***,

and 480-Volt Motor Control Center Busses A (Unit 4 only), C and D***, or

2) 4160-Volt Bus B, 480-Volt Load Center Busses B, D and H***,

See ITS and 480-Volt Motor Control Center Busses B and D***. 3.8.9

d. 120 Volt AC Vital Panel 3P06 and 3P21 energized from its associated inverter connected to D.C.

Bus 3B.**** LA01

e. 120 Volt AC Vital Panel 4P06 and 4P21 energized from its associated inverter connected to D.C.

Bus 3B.****

f. 120 Volt AC Vital Panel 3P07 and 3P22 energized from its associated inverter connected to D.C.

Bus 3A.****

g. 120 Volt AC Vital Panel 4P07 and 4P22 energized from its associated inverter connected to D.C.

Bus 3A.****

h. 120 Volt AC Vital Panel 3P08 and 3P23 energized from its associated inverter connected to D.C.

Bus 4B.****

i. 120 Volt AC Vital Panel 4P08 and 4P23 energized from its associated inverter connected to D.C.

Bus 4B.****

  • For Motor Control Center busses, vital sections only. See ITS 3.8.9
    • With the opposite unit in MODE 5, 6, or defueled, its 480-Volt Load Center can be cross-tied under conditions specified in Specification 3.8.3.2.a.
      • Electrical bus can be energized from either train of its unit and swing function to opposite train must be OPERABLE for the Unit(s) in MODES 1, 2, 3, and 4.

LA01

        • A back-up inverter may be used to replace the normal inverter provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time.

TURKEY POINT - UNITS 3 & 4 3/4 8-18 AMENDMENT NOS. 289 AND 283 Page 1 of 3

ITS ITS 3.8.7 A01 ONSITE POWER DISTRIBUTION LIMITING CONDITION FOR OPERATION (Continued)

See ITS 3.8.9

j. 120 Volt AC Vital Panel 3P09 and 3P24 energized from its associated inverter connected to D.C.

Bus 4A.**** LA01

k. 120 Volt AC Vital Panel 4P09 and 4P24 energized from its associated inverter connected to D.C.

Bus 4A.****

l. 125 Volt D.C. Bus 3D01 energized from an associated battery charger and from Battery Bank 3A or spare battery bank D-52,
m. 125 Volt D.C. Bus 3D23 energized from an associated battery charger and from Battery Bank 3B or spare battery bank D-52,
n. 125 Volt D.C. Bus 4D01 energized from an associated battery charger and from Battery Bank 4B or spare battery bank D-52, and
o. 125 Volt D.C. Bus 4D23 energized from an associated battery charger and from Battery Bank 4A or spare battery bank D-52 See ITS Applicability APPLICABILITY: MODES 1, 2, 3, and 4. 3.8.9 ACTION:

NOTE: Enter applicable ACTIONS of LCO 3.8.2.1, D.C. Sources - Operating, for DC trains made inoperable by inoperable AC power distribution system. See ITS 3.8.9

a. With one of the required trains (3.8.3.1a., b., and c) of A.C. emergency busses not fully energized (except for the required LCs and MCCs associated with the opposite unit), reenergize the train within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With any of the required LCs and/or MCCs associated with the opposite unit inoperable, restore the inoperable LC or MCC to OPERABLE status in accordance with Table 3.8-1 or Table 3.8-2 as applicable or place the unit in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

ACTION A c. With one A.C. vital panel either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) Reenergize the A.C. vital panel within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or in See ITS accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY 3.8.9 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) reenergize the A.C. vital panel from an inverter connected to its associated D.C. bus Add proposed Required Action A.1 Note A02 LA01

        • A back-up inverter may be used to replace the normal inverter, provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time.

TURKEY POINT - UNITS 3 & 4 3/4 8-19 AMENDMENT NOS. 287 AND 281 Page 2 of 3

ITS ITS 3.8.7 A01 ONSITE POWER DISTRIBUTION LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)

ACTION A within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in at ACTION B least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following See ITS 3.8.9 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units simultaneously. MODE 4 18 L01 R2 Add proposed Required Action B.2 Note

d. With one D.C. bus not energized from its associated battery bank or associated charger, reenergize the D.C. bus from its associated battery bank within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s* or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units simultaneously.

See ITS SURVEILLANCE REQUIREMENTS 3.8.9 SR 3.8.7.1 4.8.3.1 The specified busses shall be determined energized and aligned in the required manner by verifying correct breaker alignment and indicated voltage on the buses in accordance with the Surveillance Frequency Control Program.

  • Can be extended to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the opposite unit is in MODE 5, 6, or defueled and each of the remaining See ITS required battery chargers is capable of being powered from its associated diesel generator(s). 3.8.9 TURKEY POINT - UNITS 3 & 4 3/4 8-20 AMENDMENT NOS. 289 AND 283 Page 3 of 3

DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS LCO 3.8.3.1, ACTION c, states, in part, that with one AC Vital Bus either not R2 energized from its associated Inverter, or with the inverter not connected to its associated DC Bus, re-energize the AC Vital Bus from its associated inverter connected to its associated DC Bus within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS Limiting Condition for Operation (LCO) 3.8.7, ACTION A, states with one inverter inoperable, restore the Inverter to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Required Action A is modified by a note that states, "Enter applicable Condition and Required Actions of LCO 3.8.9, 'Distribution Systems - Operating,' with any AC vital bus de-energized." This changes the CTS by adding a note that references the requirements for ITS LCO 3.8.9.

This change is acceptable because it does not change the technical requirements of the CTS. The ITS rules of usage require all conditions for a system, subsystem, train, component, or device to be entered when a system, subsystem, train, component, or device become inoperable. ITS LCO 3.8.7, Condition A, is for one required inverter inoperable and LCO 3.8.9 must be entered if an AC Vital bus is inoperable. The ITS 3.8.9, Condition A Note, provides no specific technical requirements and acts only as a reminder to enter LCO 3.8.9 if an AC Vital bus has become de-energized. This change is R2 designated as administrative because the technical requirements of the specifications have not changed.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.3.1 states, in part, that the following electrical busses*

Turkey Point Unit 3 and Unit 4 Page 1 of 3

DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING shall be energized in the specified manner, listing the 120 volt AC Vital Panels as Items d through k, with the manner of energization being the associated inverter connected to the specified DC bus (e.g., its associated inverter connected to DC Bus 3B). In addition, footnote **** states that a back-up inverter may be used to replace the normal inverter provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time. ITS 3.8.7 does not contain this level of detail information. This changes the CTS by moving the level of detail of inverter alignment to the DC bus and details that a back-up inverter may R2 be used to replace the normal inverter to the ITS Bases.

The removal of these details related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.3.1, ACTION c, requires, in part, that with the inverter not connected to its associated DC bus, to reenergize the AC vital panel from an inverter connected to its associated DC bus within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. ITS 3.8.7, ACTION B, requires that with the Required Action and associated Completion Time (Restore inverter to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or in accordance with the Risk Informed Completion Time Program) of Condition A not met, to be in MODE 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 in 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. In addition, a Note is added to prevent the use of ITS LCO 3.0.4.a. This changes the CTS by requiring a less restrictive end state in the required actions, MODE 4 (HOT SHUTDOWN) instead of MODE 5 (COLD SHUTDOWN).

The purpose of the CTS 3.8.3.1 ACTION c, in part, is to ensure the unit is placed in a safe condition (end state of MODE 5) if an affected AC vital panel remains disconnected from its associated inverter beyond the specified Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.8.7, Condition B, ensures the unit is placed in a safe condition R2 if an inoperable inverter is not restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, but with an end state of MODE 4. Note that ITS 3.8.9, "Distribution Systems -

Operating," addresses a de-energized or otherwise inoperable AC vital bus. End states are usually defined based on placing the unit into a MODE or condition in which the Technical Specification LCO is not applicable. MODE 5 is the current end state for LCOs that are applicable in MODES 1 through 4. This change is acceptable because the risk of the transition from MODE 1 to MODES 4 or 5 depends on the availability of AC sources and the ability to remove decay heat such that remaining in MODE 4 may be safer. During the realignment from Turkey Point Unit 3 and Unit 4 Page 2 of 3

DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING MODE 4 to MODE 5, there is an increased potential for loss of shutdown cooling and loss of inventory events. Decay heat removal following a loss-of-offsite power event in MODE 5 is dependent on AC power for shutdown cooling whereas, in MODE 4, the turbine driven auxiliary feedwater (AFW) pump will be available. Therefore, transitioning to MODE 5 is not always the appropriate end state from a risk perspective. Thus, for specific TS conditions, Westinghouse Topical Report WCAP-16294-A, Revision 1 (ADAMS Accession No. ML103430249) justifies MODE 4 as an acceptable alternate end state to Mode 5.

The proposed change to the Technical Specifications will allow time to perform short-duration repairs, which currently necessitate exiting the original mode of applicability. The MODE 4 TS end state is applied, and risk is assessed and managed in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." Modified end states are limited to conditions where: (1) entry into the shutdown mode is for a short interval, (2) entry is initiated by inoperability of a single train of equipment or a restriction on a plant operational parameter, unless otherwise stated in the applicable TS, and (3) the primary purpose is to correct the initiating condition and return to power operation as soon as is practical. This proposed change is consistent with NRC approved TSTF-432-A, Revision 1 (ADAMS Accession No. ML103360003),

noticed for availability by the NRC in the Federal Register (77 FR 27814) on May 11, 2012. The NRC's approval of WCAP-16294-A included four limitations and conditions on its use as identified in Section 4.0 of the NRC Safety Evaluation associated with WCAP-16294-A. Implementation of these stipulations were addressed in the Bases of TSTF-432-A. Florida Power & Light Company implemented these limitations and conditions at PTN in the adoption of the associated TSTF-432-A Bases. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Turkey Point Unit 3 and Unit 4 Page 3 of 3

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS Inverters - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating 3.8.3.1 LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE. 1

NOTE--------------------------------------------

[ [One/two] inverter[s] may be disconnected from [its/their] associated DC bus for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform an equalizing charge on [its/their]

associated [common] battery, provided:

a. The associated AC vital bus(es) [is/are] energized from [its/their] 2

[Class 1E constant voltage source transformers] [inverter using internal AC source], and

b. All other AC vital buses are energized from their associated OPERABLE inverters. ]

Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION c A. One [required] inverter A.1 --------------NOTE-------------- 2 inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution DOC A02 Systems - Operating" with any AC vital bus de-energized.

Restore inverter to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OPERABLE status.

[OR 2 In accordance with the Risk Informed Completion Time Program] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.7-1 Rev. 5.0 1

CTS Inverters - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 12 ACTION c B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 1 associated Completion Time not met. AND B.2 --------------NOTE--------------

LCO 3.0.4.a is not DOC L01 applicable when entering MODE 4.

18 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.3.1 SR 3.8.7.1 Verify correct inverter voltage, [frequency], and [ 7 days alignment to required AC vital buses. 2 OR In accordance with the Surveillance Frequency Control Program ] 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.7-2 Rev. 5.0 1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.7, INVERTERS - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Inverters - Operating B 3.8.7 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.7 Inverters - Operating BASES BACKGROUND The inverters are the preferred source of power for the AC vital buses because of the stability and reliability they achieve. The function of the inverter is to provide AC electrical power to the vital buses. The inverters INSERT 1 can be powered from an internal AC source/rectifier or from the station 1 battery. The station battery provides an uninterruptible power source for the instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Feature Actuation System (ESFAS). Specific U

details on inverters and their operating characteristics are found in the FSAR, Chapter [8] (Ref. 1). 1 2 APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient 14 U

SAFETY analyses in the FSAR, Chapter [6] (Ref. 2) and Chapter [15] (Ref. 3), 1 2 ANALYSES assume Engineered Safety Feature systems are OPERABLE. The inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the RPS and ESFAS instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and is based on meeting the design basis of the unit. This includes maintaining required AC vital buses OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite AC electrical power or all onsite AC 1

electrical power and

b. A worst case single failure.

Inverters are a part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The inverters ensure the availability of AC electrical power for the systems instrumentation required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.7-1 Rev. 5.0 1

B 3.8.7 1

INSERT 1 The 120 VAC Instrument System has four sets of equipment for each unit, each set consisting of a 7.5 kVA, 125 VDC/120 VAC inverter, distribution panel, static transfer switch and an associated constant voltage transformer (CVT) for alternate 120 VAC supplied from a vital motor control center (MCC). Each inverter is normally powered by a separate bus of the vital DC system. Upon overload or loss of the inverter AC output, the static switch in the output of the inverter automatically fast transfers to the alternate AC supply (CVT), if available, to maintain continuity of output power.

Four 7.5 kVA, 125 VDC/120 VAC spare inverters are provided to allow maintenance on the normal inverters. One spare inverter is provided for each pair of normal inverters of the same channel. The spare inverters are manually placed in service and can serve as backup to the normal source for each unit.

Insert Page B 3.8.7-1

Inverters - Operating B 3.8.7 BASES LCO (continued)

Maintaining the required inverters OPERABLE ensures that the redundancy incorporated into the design of the RPS and ESFAS 8 required instrumentation and controls is maintained. The four inverters [(two per 1 2

train)] ensure an uninterruptible supply of AC electrical power to the AC vital buses even if the 4.16 kV safety buses are de-energized.

OPERABLE inverters require the associated vital bus to be powered by the inverter with output voltage and frequency within tolerances, and INSERT 2 power input to the inverter from a [125 VDC] station battery. Alternatively, 1 power supply may be from an internal AC source via rectifier as long as the station battery is available as the uninterruptible power supply.

This LCO is modified by a Note that allows [one/two] inverters to be disconnected from a [common] battery for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, if the vital bus(es) is powered from a [Class 1E constant voltage transformer or inverter using internal AC source] during the period and all other inverters are operable. This allows an equalizing charge to be placed on one battery.

If the inverters were not disconnected, the resulting voltage condition might damage the inverter[s]. These provisions minimize the loss of equipment that would occur in the event of a loss of offsite power. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period for the allowance minimizes the time during which a 3 loss of offsite power could result in the loss of equipment energized from the affected AC vital bus while taking into consideration the time required to perform an equalizing charge on the battery bank.

The intent of this Note is to limit the number of inverters that may be disconnected. Only those inverters associated with the single battery undergoing an equalizing charge may be disconnected. All other inverters must be aligned to their associated batteries, regardless of the number of inverters or unit design.

APPLICABILITY The inverters are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and
b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Inverter requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.8, "Inverters - Shutdown."

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.7-2 Rev. 5.0 1

B 3.8.7 1

INSERT 2 the connected 125 VDC bus shown in Table B 3.8.7-1.

Insert Page B 3.8.7-2

Inverters - Operating B 3.8.7 BASES ACTIONS A.1 With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is [manually] re-energized from its [Class 1E constant 2

voltage source transformer or inverter using internal AC source].

For this reason a Note has been included in Condition A requiring the entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." This ensures that the vital bus is re-energized within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Required Action A.1 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fix the inoperable inverter and return it to service. [Alternatively, a Completion Time can be determined 2 in accordance with the Risk Informed Completion Time Program.] The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit is based upon engineering judgment, taking into consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety systems such a shutdown might entail.

When the AC vital bus is powered from its constant voltage source, it is relying upon interruptible AC electrical power sources (offsite and onsite).

The uninterruptible inverter source to the AC vital buses is the preferred source for powering instrumentation trip setpoint devices.

B.1 and B.2 If the inoperable devices or components cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to 1

MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. 12 18 Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

R2 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.7-3 Rev. 5.0 1

Inverters - Operating B 3.8.7 BASES ACTIONS (continued)

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or 4 other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.8.7.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation of the RPS and ESFAS connected to the AC vital buses. [ The 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator 2

to inverter malfunctions.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

INSERT 3 R2 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.7-4 Rev. 5.0 1

B 3.8.7 1

INSERT 3 R2 Table B 3.8.7-1 120 Volt AC Vital Panel(s) Inverter (1) Back-up Inverter D.C. Bus 3P07 and 3P22 3A AS 3A 4P07 and 4P22 4A 3P08 and 3P23 3B BS 4B 4P08 and 4P23 4B 3P06 and 3P21 3C CS 3B 4P06 and 4P21 4C 3P09 and 3P24 3D DS 4A 4P09 and 4P24 4D (1) A back-up inverter may be used to replace the normal inverter, provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time.

Insert Page B 3.8.7-4

Inverters - Operating B 3.8.7 BASES U

REFERENCES 1. FSAR, Chapter [8]. 1 2 U

2. FSAR, Chapter [6]. 1 2 U 14
3. FSAR, Chapter [15]. 1 2
4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.7-5 Rev. 5.0 1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.7 BASES, INVERTERS - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. This allowance of the ISTS Limiting Condition for Operation (LCO) 3.8.7 Note has been deleted because Turkey Point Nuclear Generating Station (PTN) does not need to disconnect the 120 VAC vital bus during an equalizing charge.
4. Editorial/grammar changes to the Bases have been made to enhance clarity.
5. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.7, INVERTERS - OPERATING There are no specific No Significant Hazards Considerations for this Specification.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

ATTACHMENT 8 ITS 3.8.8, INVERTERS - SHUTDOWN

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS A01 ITS 3.8.8 ONSITE POWER DISTRIBUTION SHUTDOWN LIMITING CONDITION FOR OPERATION A02 Add proposed LCO 3.8.8 LCO 3.8.8 3.8.3.2 As a minimum, the following electrical busses shall be energized in the specified manner: See ITS 3.8.10

a. One train of A.C. emergency busses associated with the unit (3.8.3.1a. or b.) consisting of one 4160-volt and three 480-volt A.C. emergency busses load centers* and three (four for Unit 4 Train A) vital sections of motor control center busses, LA01
b. Two 120-volt A.C. vital busses for the unit energized from their associated inverters** connected to their respective D.C. busses, and LA02
c. Three 125-volt D.C. busses energized from their associated battery banks. See ITS 3.8.10 A03 Applicability APPLICABILITY MODES 5*** and 6***.

, During movement of irradiated fuel assemblies. M01 ACTION:

Add ACTIONS Note With any of the above required electrical busses not energized in the required manner, immediately suspend all Action A operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel, initiate corrective action to energize the required electrical busses in the specified manner as soon as possible, and L01 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the RCS through at least a 2.2 square inch vent.

Add proposed Required Actions A.1 and A.2.2 L02 SURVEI LLANCE REQUIREMENTS SR 3.8.8.1 4.8.3.2 The specified busses shall be determined energized in the required manner by verifying correct breaker alignment and indicated voltage on the busses in accordance with the Surveillance Frequency Control Program.

and frequency inverter M02 See ITS 3.8.10

  • With the opposite unit in MODE 1, 2, 3, or 4, the 480-volt load centers can only be cross-tied upon issuance of an engineering evaluation to prevent exceeding required electrical components maximum design ratings and to ensure availability of the minimum required equipment.
    • A backup inverter may be used to replace the normal inverter provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time.

LA01

      • CAUTION - If the opposite unit is in MODES 1, 2, 3, or 4, see the corresponding Limiting Condition for Operation 3.8.3.1. A03 TURKEY POINT - UNITS 3 & 4 3/4 8-23 AMENDMENT NOS. 263 AND 258 Page 1 of 1

DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.3.2 requires, in part, that as a minimum, the following electrical busses shall be energized in the specified manner, listing two associated inverters connected to their respective DC busses. ITS 3.8.8 requires that two inverters shall be OPERABLE. This changes the CTS by providing a specific Limiting Condition for Operation (LCO) for inverters.

The purpose of CTS 3.8.3.2 is to ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated Design Basis Accident (DBA). The change is acceptable because ITS 3.8.8 maintains this purpose for the part associated with the inverters. No changes are made to CTS inverter requirements. The change is in format from CTS to ITS and maintains the inverters technical requirements. This change is designated as administrative because it does not result in a technical change to the CTS.

A03 CTS 3.8.3.2 (ITS 3.8.8) is applicable in MODES 5 and 6. The CTS 3.8.3.2 Applicability is modified by a Note *** which states, "CAUTION - If the opposite unit is in MODES 1, 2, 3, or 4, see the corresponding Limiting Condition for Operation 3.8.3.1." ITS 3.8.8 does not contain a similar Note. This changes the CTS by deleting a requirement that is redundant to CTS 3.0.5, which is retained in ITS.

The purpose of the CTS 3.8.3.2 Applicability Note is to ensure appropriate action requirements are performed for equipment shared between both units when required for a specific MODE of operation. This Note is redundant to the generic requirement provided in CTS 3.0.5 (ITS LCO 3.0.10) and, therefore, is not necessary. CTS 3.0.5 states, in part, "Limiting Conditions for Operation including the associated ACTION requirements shall apply to each unit individually unless otherwise indicated This requirement is retained in ITS LCO 3.0.10. As a result, Technical Specification requirements are applicable to each unit and apply, based on the units applicable MODE, to the requirements associated with an LCO that refers to systems and components shared by both units, irrespective of whether an explicit statement is provided or not. The appropriate Technical Specification ACTIONS associated with shared systems will continue to be performed for each unit based on the units applicable MODE or specified condition per the requirements of ITS LCO 3.0.10. This change is designated as Turkey Point Unit 3 and Unit 4 Page 1 of 5

DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN an administrative change and is acceptable because the change does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.3.2 is applicable in MODES 5 and 6. ITS LCO 3.8.8 is applicable in MODES 5 and 6 and during movement of irradiated fuel assemblies. A Note has been added to the ACTIONS which states that LCO 3.0.3 is not applicable. This changes the CTS by adding the Applicability of during movement of irradiated fuel assemblies and adds the Note to the ACTIONS stating that LCO 3.0.3 is not applicable.

This change is acceptable because the proposed requirements are necessary to ensure the inverters are OPERABLE to support equipment required to be OPERABLE during movement of irradiated fuel assemblies. Movement of fuel normally occurs during MODES 5 and 6, however, it can also occur outside of containment in other plant MODES (MODES 1, 2, 3, and 4) or other conditions (i.e., reactor defueled). This Specification is needed to ensure the appropriate requirements are specified during fuel handling and ensure the appropriate ACTIONS are taken (i.e., stop fuel movement) when the minimum electrical supply is not available. This change adds a clarification Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable and would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with the ITS 3.8.8 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary because defaulting to LCO 3.0.3 would require the reactor to be shut down but would not require suspension of activities with a potential for releasing radioactive materials. This change is designated as more restrictive because the ITS requires the equipment to be OPERABLE during movement of irradiated fuel assemblies both inside and outside of the containment, not only in MODES 5 and 6.

M02 CTS 4.8.3.2 requires that specified busses shall be determined energized in the required manner by verifying correct breaker alignment and indicated voltage on the busses. ITS Surveillance Requirement (SR) 3.8.8.1 requires the verification of correct inverter voltage, frequency, and alignments to required AC vital buses.

This changes the CTS by requiring the specific verification of the inverter voltage, frequency, and alignment.

The purpose of CTS 4.8.3.2 is to ensure the instrumentation channels are provided with the proper voltage when powered by the associated inverter. This change is acceptable because the Surveillance will continue to verify OPERABILITY of the required inverters by verifying proper voltage and frequency are supplied to the instrumentation channels that provide inputs to the Reactor Trip System and Engineered Safety Features Actuation System. This change is designated as more restrictive because the ITS requires verification of Turkey Point Unit 3 and Unit 4 Page 2 of 5

DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN the correct inverter voltage, frequency, and alignment where the CTS does not provide explicit requirements for the inverter.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.3.2 footnote ** states that a backup inverter may be R2 used to replace the normal inverter provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time. ITS 3.8.8 requires, in part, the inverters to be OPERABLE. This changes the CTS by moving this level of detail information into the ITS Bases.

The removal of these details related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.3.2 states, in part, that as a minimum, the following electrical busses shall be energized in the specified manner, listing two 120-volt AC vital busses for the unit and energized from their associated inverters**

connected to their respective DC busses. ITS 3.8.8 LCO states that two inverters shall be OPERABLE. This changes the CTS by moving this level of detail information into the ITS Bases.

The removal of these details related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.8.3.2 ACTION requires, in part, that with any of the above required electrical busses not energized in the Turkey Point Unit 3 and Unit 4 Page 3 of 5

DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN required manner, the Reactor Coolant System (RCS) must be depressurized and vented within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> through at least a 2.2 square inch vent. ISTS 3.8.8 does not include this Required Action. ITS LCO 3.4.12, "Overpressure Mitigation System," provides requirements for RCS pressure relief when in MODES 4, 5, or 6, to depressurize and establish an RCS vent of 2.2 square inches within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the other pressure relief methods are incapable of limiting pressure. R2 This changes the CTS by relying on ITS LCO 3.4.12 to provide the Required Actions and allowing a longer Completion Time to depressurize the RCS and establish a 2.2 square inch RCS vent.

The purpose of CTS 3.8.3.2 ACTION is to provide remedial actions to be taken with any of the above required electrical busses not energized in the required manner while in MODE 5 or 6. One of these remedial actions is to depressurize and vent the RCS through at least a 2.2 square inch vent, which is being proposed for deletion. This change is acceptable because the CTS 3.8.3.2 ACTION to depressurize and vent the RCS is duplicative of the ITS LCO 3.4.12 Required Action to depressurize and vent the RCS. In addition, ITS 3.4.12 Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the allowed Completion Time. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 3.8.3.2 ACTION states, in part, that that with any of the above required electrical busses not energized in the required manner, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel.

ITS 3.8.8, Required Actions A.1, A.2.1, and A.2.2, provide Actions to be performed under similar conditions. These ITS Required Actions state to declare affected required feature(s) inoperable, or to suspend movement of irradiated fuel assemblies and suspend operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN (SDM) or boron concentration. This changes the CTS Actions by deleting the requirement to suspend CORE ALTERATIONS and to clarify to only suspend positive reactivity additions when it could result in loss of required SDM or boron concentration.

The purpose of the CTS 3.8.3.2 ACTION is to minimize the possibility of an event that may need a required electrical bus to mitigate the consequences of the event. CORE ALTERATIONS is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel."

CORE ALTERATIONS only occur when the reactor vessel head is removed and only applies in MODE 6. There is only one accident considered during MODE 6 that involves CORE ALTERATIONS: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building.

Suspension of CORE ALTERATIONS, except for suspension of movement of Turkey Point Unit 3 and Unit 4 Page 4 of 5

DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN irradiated fuel, would not prevent or impair the mitigation of a fuel handling accident.

ITS 3.8.8 retains the requirement to suspend movement of irradiated fuel assemblies in ITS 3.8.8, Required Action A.2.1 (for an inoperable inverter).

Therefore, because the only CORE ALTERATION analyzed in the safety analysis and potentially affected by a loss of an inverter is covered by the ITS Required Actions, deleting the reference to "CORE ALTERATIONS" is acceptable. Additionally, CORE ALTERATIONS that may be capable of R2 damaging a fuel assembly prior to the 72-hour decay period is improbable because the physical time required to perform plant shutdown, cooldown, depressurize the Reactor Coolant System, and the additional operations required to expose the irradiated fuel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

CTS 3.8.3.2 ACTION also requires that with less than the above minimum required electrical busses, immediately suspend all operations involving positive reactivity changes while ITS 3.8.8, Required Actions A.2.2, requires only the suspension of positive reactivity additions that could result in loss of required SDM or boron concentration. This change is acceptable because it allows for positive reactivity additions that do not result in loss of required SDM or boron concentration (e.g., water addition or temperature change) assuring continued safe operation.

With the addition of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required Actions.

However, in many instances, this option may involve undesired administrative efforts. Therefore, the allowance for suspending movement of irradiated fuel assemblies and suspending operations involving positive reactivity additions that could result in loss of required SDM or boron concentration are sufficiently conservative actions. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Turkey Point Unit 3 and Unit 4 Page 5 of 5

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown 3.8.3.2 LCO 3.8.8 [Inverters shall be OPERABLE to support the onsite Class 1E AC vital bus electrical power distribution subsystem(s) required by LCO 3.8.10, 1 "Distribution Systems - Shutdown."]

Two

[One] inverter[s] shall be OPERABLE.] 1

REVIEWER'S NOTE-----------------------------------

This second option above applies for plants having a pre-ITS licensing basis (CTS) for electrical power requirements during shutdown conditions that required only [one] inverter to be OPERABLE. The "[or more]"

optional wording in Condition A is also eliminated for this case. The first 2 option above is adopted for plants that have a CTS requiring the same level of DC electrical power subsystem/inverter support as is required for power operating conditions.

Applicability APPLICABILITY: MODES 5 and 6, During movement of [recently] irradiated fuel assemblies. 1 ACTIONS

NOTE-----------------------------------------------------------

DOC M01 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME Action A. One [or more] [required] A.1 Declare affected required Immediately 1 inverter[s] inoperable. feature(s) inoperable.

OR A.2.1 Suspend movement of Immediately

[recently] irradiated fuel 1 assemblies.

AND Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.8-1 Rev. 5.0 3

CTS Inverters - Shutdown 3.8.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2.2 Suspend operations Immediately involving positive reactivity DOC L02 additions that could result in loss of required SDM or boron concentration.

AND A.2.3 Initiate action to restore Immediately required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.3.2 SR 3.8.8.1 Verify correct inverter voltage, [frequency,] and [ 7 days alignments to required AC vital buses. 1 OR In accordance with the Surveillance Frequency Control Program ] 1 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.8-2 Rev. 5.0 3

JUSTIFICATION FOR DEVIATIONS ITS 3.8.8, INVERTERS - SHUTDOWN

1. The Improved Standard Technical Specification (ISTS) contain bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
2. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Inverters - Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters - Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient 14 U

SAFETY analyses in the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), 3 1 ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC to AC inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the Reactor Protective System and Engineered Safety Features Actuation System instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum inverters to each AC vital bus during MODES 5 and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident [involving handling recently irradiated fuel. Due to radioactive decay, the AC and DC inverters are only required to mitigate fuel handling accidents 1 involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days).].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many DBAs that are analyzed in MODES [1, 2, 3, and 4] have no specific analyses in 1 MODES [5 and 6] because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.8-1 Rev. 5.0 3

Inverters - Shutdown B 3.8.8 BASES APPLICABLE SAFETY ANALYSES (continued) significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.

The inverters were previously identified as part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The inverter[s] ensure the availability of electrical power for the 1 instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. The battery powered inverter[s] provide[s] 1 uninterruptible supply of AC electrical power to the AC vital bus[es] even if the 4.16 kV safety buses are de-energized. OPERABILITY of the and the inverter input connected to its inverter[s] requires that the AC vital bus be powered by the inverter. This 1 R2 respective DC bus ensures the availability of sufficient inverter power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling 1

recently irradiated fuel]).

APPLICABILITY The inverter[s] required to be OPERABLE in MODES 5 and 6 and during 1

movement of [recently] irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,
b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 1 critical reactor core within the previous [X] days)] are available, Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.8-2 Rev. 5.0 3

Inverters - Shutdown B 3.8.8 BASES APPLICABILITY (continued)

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A.1, A.2.1, A.2.2, and A.2.3

[If two trains are required by LCO 3.8.10, "Distribution Systems - 1 Shutdown," the remaining OPERABLE Inverters may be capable of supporting sufficient required features to allow continuation of [recently] 1 irradiated fuel movement, and operations with a potential for positive reactivity additions.] By the allowance of the option to declare required 1 features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend movement of

[recently] irradiated fuel assemblies, and operations involving positive 1 reactivity additions) that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.8-3 Rev. 5.0 3

Inverters - Shutdown B 3.8.8 BASES ACTIONS (continued)

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required inverter[s] and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation connected to the AC vital buses. [ The 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter 1

malfunctions.

OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 2 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

REFERENCES 1. FSAR, Chapter [6]. 3 1 U 14

2. FSAR, Chapter [15]. 3 1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.8-4 Rev. 5.0 3

JUSTIFICATION FOR DEVIATIONS ITS 3.8.8 BASES, INVERTERS - SHUTDOWN

1. The Improved Standard Technical Specification (ISTS) contain bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
2. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.8, INVERTERS - SHUTDOWN There are no specific No Significant Hazards Considerations for this Specification.

Turkey Point Unit 3 and 4 Page 1 of 1

ATTACHMENT 9 ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS A01 ITS 3.8.9 R2 3/4.8.3 ONSITE POWER DISTRIBUTION OPERATING LIMITING CONDITION FOR OPERATION LCO 3.8.9 3.8.3.1 The following electrical busses* shall be energized in the specified manner with the tie breakers open between redundant busses within the unit** and between the busses of Units 3 and 4.

LA02 LCO 3.8.9.a a. One train of A.C. Busses consisting of:

1) 4160-Volt Bus A, LA03
2) 480-Volt Load Center Busses A, C and H***, and
3) 480-Volt Motor Control Center Busses A (Unit 4 only),C and D***,

LCO 3.8.9.a b. One train of A.C. Busses consisting of:

LA01

1) 4160-Volt Bus B
2) 480-Volt Load Center Busses B, D and H***, and
3) 480-Volt Motor Control Center Busses B and D***

Required M01 LCO 3.8.9.b c. One opposite unit train of AC busses consisting of either:

1) 4160-Volt Bus A, 480-Volt Load Center Busses A, C and H***,

and 480-Volt Motor Control Center Busses A (Unit 4 only), C and D***, or

2) 4160-Volt Bus B, 480-Volt Load Center Busses B, D and H***,

and 480-Volt Motor Control Center Busses B and D***. See ITS 3.8.7 LCO 3.8.9.d, d. 120 Volt AC Vital Panel 3P06 and 3P21 energized from its associated inverter connected to D.C.

LCO 3.8.9.e Bus 3B.**** L01 or Class 1E constant voltage transformer LCO 3.8.9.d, e. 120 Volt AC Vital Panel 4P06 and 4P21 energized from its associated inverter connected to D.C.

LCO 3.8.9.e Bus 3B.**** See ITS 3.8.7 LCO 3.8.9.d, f. 120 Volt AC Vital Panel 3P07 and 3P22 energized from its associated inverter connected to D.C.

LCO 3.8.9.e Bus 3A.**** L01 or Class 1E constant voltage transformer LCO 3.8.9.d, g. 120 Volt AC Vital Panel 4P07 and 4P22 energized from its associated inverter connected to D.C.

LCO 3.8.9.e Bus 3A.**** See ITS 3.8.7 LCO 3.8.9.d, h. 120 Volt AC Vital Panel 3P08 and 3P23 energized from its associated inverter connected to D.C.

LCO 3.8.9.e Bus 4B.**** L01 or Class 1E constant voltage transformer LCO 3.8.9.d, i. 120 Volt AC Vital Panel 4P08 and 4P23 energized from its associated inverter connected to D.C.

LCO 3.8.9.e Bus 4B.**** See ITS 3.8.7

  • For Motor Control Center busses, vital sections only. LA03
    • With the opposite unit in MODE 5, 6, or defueled, its 480-Volt Load Center can be cross-tied under conditions specified in Specification 3.8.3.2.a. LA02
      • Electrical bus can be energized from either train of its unit and swing function to opposite train must be LA01 OPERABLE for the Unit(s) in MODES 1, 2, 3, and 4. See ITS 3.8.7
        • A back-up inverter may be used to replace the normal inverter provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time.

TURKEY POINT - UNITS 3 & 4 3/4 8-18 AMENDMENT NOS. 289 AND 283 Page 1 of 5 6

ITS A01 ITS 3.8.9 R2 ONSITE POWER DISTRIBUTION LA02 LIMITING CONDITION FOR OPERATION (Continued)

See ITS 3.8.7 LCO 3.8.9.d, j. 120 Volt AC Vital Panel 3P09 and 3P24 energized from its associated inverter connected to D.C.

LCO 3.8.9.e Bus 4A.**** or Class 1E constant voltage transformer L01 LCO 3.8.9.d, k. 120 Volt AC Vital Panel 4P09 and 4P24 energized from its associated inverter connected to D.C.

LCO 3.8.9.e Bus 4A.**** See ITS 3.8.7 LCO 3.8.9.c l. 125 Volt D.C. Bus 3D01 energized from an associated battery charger and from Battery Bank 3A or spare battery bank D-52, or L02 LCO 3.8.9.c m. 125 Volt D.C. Bus 3D23 energized from an associated battery charger and from Battery Bank 3B or spare battery bank D-52, LCO 3.8.9.c n. 125 Volt D.C. Bus 4D01 energized from an associated battery charger and from Battery Bank 4B or spare battery bank D-52, and or LCO 3.8.9.c o. 125 Volt D.C. Bus 4D23 energized from an associated battery charger and from Battery Bank 4A or spare battery bank D-52 LA04 R2 Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

L03 Required Action A.1 NOTE: Enter applicable ACTIONS of LCO 3.8.2.1, D.C. Sources - Operating, for DC trains made Note inoperable by inoperable AC power distribution system.

or more LA03 Action A a. With one of the required trains (3.8.3.1a., b., and c) of A.C. emergency busses not fully energized (except for the required LCs and MCCs associated with the opposite unit), reenergize the train within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in at L04 Action E least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Add proposed Required Action E.2 and Note LA03

b. With any of the required LCs and/or MCCs associated with the opposite unit inoperable, restore the inoperable LC or MCC to OPERABLE status in accordance with Table 3.8-1 or Table 3.8-2 as applicable or place the unit in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. L03 or more LA01 or Class 1E constant voltage transformer Action B See ITS c. With one A. C. vital panel either not energized from its associated inverter, or with the inverter not 3.8.7 connected to its associated D.C. bus: (1) Reenergize the A.C. vital panel within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or in L01 accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY Action F within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) reenergize the A.C. vital panel from an inverter connected to its associated D.C. bus See ITS 3.8.7 Add proposed Required Action F.2 and Note L05 See ITS 3.8.7
        • A back-up inverter may be used to replace the normal inverter, provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time.

TURKEY POINT - UNITS 3 & 4 3/4 8-19 AMENDMENT NOS. 287 AND 281 Page 2 of 5

ITS A01 ITS 3.8.9 R2 ONSITE POWER DISTRIBUTION LIMITING CONDITION FOR OPERATION (Continued)

See ITS ACTION: (Continued) 3.8.7 A02 R2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units simultaneously. L03 or more Action C d. With one D.C. bus not energized from its associated battery bank or associated charger, L02 Action D reenergize the D.C. bus from its associated battery bank within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s* or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next A02 Action F 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units simultaneously. Add proposed Required Action F.2 and Note Add proposed Action G L05 SURVEILLANCE REQUIREMENTS L03 SR 3.8.9.1 4.8.3.1 The specified busses shall be determined energized and aligned in the required manner by verifying correct breaker alignment and indicated voltage on the buses in accordance with the Surveillance Frequency Control Program.

Condition C Note L06 Action C

  • Can be extended to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the opposite unit is in MODE 5, 6, or defueled and each of the remaining required battery chargers is capable of being powered from its associated diesel generator(s).

TURKEY POINT - UNITS 3 & 4 3/4 8-20 AMENDMENT NOS. 289 AND 283 Page 3 of 5

ITS A01 ITS 3.8.9 R2 LA03 TABLE 3.8-1 APPLICABLE TO UNIT 3 BASED ON UNIT 4 LOAD CENTERS AND MOTOR CONTROL CENTERS INOPERABLE ALLOWABLE OUTAGE TIMES Unit 4 Load Centers and Motor Allowable Outage Times (hours)

Control Centers Unit 3 - MODES 1, 2, 3 and 4 Inoperable (Any MODE)

With AC With AC With AC Trains 3A, 3B, Trains 3A, Trains 3A, 4A, & 4B 3B, & 4A 3B, & 4B OPERABLE OPERABLE OPERABLE LC 4A N/A 72a N/A LA03 MCC 4A N/A N/A N/A LC 4C and/or MCC 4C 2*a 2*a N/A LC 4H and/or MCC 4D 2**a 2**a 2**a A03 LC 4B and/or MCC 4B 2*a N/A 2*a LC 4D N/A N/A 72a LA03 A03

  • If the battery charger powered from the out-of-service LC and/or MCC is not required by LCO 3.8.2.1, the out-of-service time is not applicable (N/A).
    • If neither of the battery chargers powered from the out-of-service LC and/or MCC is required by LCO 3.8.2.1, the out-of-service time is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program.

a or in accordance with the Risk Informed Completion Time Program.

LA03 TURKEY POINT - UNITS 3 & 4 3/4 8-21 AMENDMENT NOS. 284 AND 278 Page 4 of 5

ITS A01 ITS 3.8.9 R2 LA03 TABLE 3.8-2 APPLICABLE TO UNIT 4 BASED ON UNIT 3 LOAD CENTERS AND MOTOR CONTROL CENTERS INOPERABLE ALLOWABLE OUTAGE TIMES Unit 3 Load Centers and Motor Allowable Outage Times (hours)

Control Centers Unit 4 - MODES 1, 2, 3 and 4 Inoperable (Any MODE)

With AC With AC With AC Trains 4A, 4B, Trains 4A, Trains 4A, 3A, & 3B 4B, & 3A 4B, & 3B OPERABLE OPERABLE OPERABLE LC 3A N/A 72a N/A LA03 LC 3C and/or MCC 3C 2*a 2*a N/A LC 3H and/or MCC 3D 2**a 2**a 2**a A03 LC 3B and/or MCC 3B 2*a N/A 2*a LC 3D N/A N/A 72a LA03 A03

  • If the battery charger powered from the out-of-service LC and/or MCC is not required by LCO 3.8.2.1, the out-of-service time is not applicable (N/A).
    • If neither of the battery chargers powered from the out-of-service LC and/or MCC is required by LCO 3.8.2.1, the out-of-service time is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program.

a or in accordance with the Risk Informed Completion Time Program.

LA03 TURKEY POINT - UNITS 3 & 4 3/4 8-22 AMENDMENT NOS. 284 AND 278 Page 5 of 5

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.3.1, Actions c and d, includes a statement that the action applies to both units simultaneously. ITS 3.8.9, does not explicitly state that the ACTIONS apply to both units since the statement is redundant to the requirements of CTS 3.0.5.a (ITS LCO 3.0.10.a). This changes the CTS by deleting redundant detail.

The purpose of the CTS statement is to ensure action requirements are performed simultaneously for both units when required equipment shared between the units is inoperable. This statement is redundant to the generic requirement provided in CTS 3.0.5.a (ITS LCO 3.0.10.a) and therefore is not necessary. ITS Limiting Condition for Operation (LCO) 3.0.10.a states, "Whenever the LCO refers to systems or components which are shared by both units, the Conditions and Required Actions will apply to both units simultaneously." As a result, applying Technical Speciation requirements to both units simultaneously is required to all requirements associated with an LCO that refers to systems and components shared by both units, irrespective of whether an explicit statement is provided or not. Technical Specification ACTIONS associated with shared systems will continue to be performed for both units simultaneously per the requirements of ITS LCO 3.0.10.

This change is solely a presentation preference and is designated as administrative because it does not result in a technical change to the CTS.

A03 CTS 3.8.3.1 provides requirements for electrical buses to be energized. A Note to the Actions of CTS 3.8.3.1 requires entry into the applicable Actions of LCO 3.8.2.1, DC Sources - Operating, for DC trains made inoperable by inoperable AC power distribution system. CTS 3.8.3.1, Action b, provides the required actions for the condition with any of the required load centers (LCs) and/or motor control centers (MCCs) associated with the opposite unit inoperable. The required actions stated in Action b is to restore the inoperable LC or MCC to OPERABLE status in accordance with Table 3.8-1 or Table 3.8-2, as applicable, or shutdown the unit. CTS Table 3.8-1 provides an allowable outage time (AOT) of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for LCs 4B, 4C, and 4H, and MCCs 4B, 4C, and 4D with three footnotes. The

  • footnote states, If the battery charger powered from the out-of-service LC and/or MCC is not required by LCO 3.8.2.1, the out-of-service time is not applicable (N/A). The ** footnote states, If neither of the battery chargers powered from the out-of-service LC and/or MCC is required by LCO 3.8.2.1, the out-of-service time is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Turkey Point Unit 3 and Unit 4 Page 1 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Completion Time Program. Footnote a provides an additional AOT of in accordance with the Risk Informed Completion Time Program. CTS Table 3.8-2 provides similar AOT requirements for LCs 3B, 3C, and 3H, and MCCs 3B, 3C, and 3D.

ITS LCO 3.8.9 requires two unit AC electrical power distribution trains and Required Action A.1 provides a note similar to the CTS 3.8.3.1 Action Note that states, Enter applicable Conditions and Required Actions of LCO 3.8.4, DC Sources - Operating, for DC power trains made inoperable by inoperable power distribution trains. However, ITS 3.8.9 does not specify specific AOTs or the associated footnotes for the opposite unit LCs and MCCs associated with the 125 VDC battery chargers because it is duplicative the actions associated with ITS 3.8.4. This changes the CTS by deleting duplicative information.

The purpose of the applicable CTS actions is to ensure appropriate compensatory actions are taken in the event an LC or MCC is inoperable that impacts equipment required for the opposite unit (e.g., 125 VDC battery charger).

The note to the CTS 3.8.3.1 Actions (ITS 3.8.9, Required Action A.1 Note) require entry into the actions of CTS 3.8.2.1 (ITS 3.8.4). The AOT of the battery chargers specified in CTS 3.8.2.1 Action b is equivalent to the AOTs provided in CTS Tables 3.8-1 and 3.8-2 for LCs and MCCs that supply power to the 125 VDC battery chargers. Therefore, it is unnecessary to duplicate the AOTs in ITS 3.8.9. This change is designated as administrative because other ITS specifications provide similar action requirements.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.3.1 requires electrical buses to be energized in the specific manner with tie breakers open between redundant buses within the unit and between the buses of Units 3 and 4. CTS 3.8.3.1.c requires one opposite unit train of AC buses and lists the specific 4160 V bus, 480 V load centers, and 480 V motor control centers required to meet the requirement. ITS LCO 3.8.9.b requires the opposite unit AC electrical power distribution train(s) that support equipment required by LCO 3.5.2, ECCS - Operating, LCO 3.7.10, Control Room Emergency Ventilation System (CREVS), LCO 3.7.11, Control Room Emergency Air Temperature Control System (CREATCS)," and LCO 3.8.4, DC Sources - Operating, to be OPERABLE. This changes the CTS by requiring both opposite unit AC electrical power distribution trains when needed to support loads required by other Specifications.

The purpose of ITS LCO 3.8.9 is to ensure adequate AC electrical power distribution trains are available to support required equipment. The CTS requirement only requires one train of the opposite unit AC Electrical Power Distribution System. However, one or both opposite unit trains may be required to support the emergency core cooling system (ECCS), control room emergency ventilation system (CREVS), control room emergency air temperature control system (CREATCS), and DC Sources based on the AC Electrical Distribution System lineup. CTS LCO 3.5.2 requires, in part, four safety injection (SI) pumps, each capable of being powered from its associated OPERABLE diesel generator Turkey Point Unit 3 and Unit 4 Page 2 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING except when the opposite unit is in MODE 4, 5, 6, or defueled. CTS LCO 3.8.2.1 requires all four 125V battery banks and associated battery chargers to be OPERABLE. Thus, when the four batteries are aligned to their normal battery chargers, all AC electrical power distribution trains (two unit and two opposite unit trains) are required to be OPERABLE. Additionally, to support accident analyses in the event of a design basis accident, loss of offsite power, and the failure of a Class 1E electrical bus, an opposite unit electrical power distribution train is required to support CREVS and CREATCS components. Therefore, ITS LCO 3.8.1.b requires the opposite unit AC electrical power distribution train(s) to be OPERABLE to support the requirements of LCO 3.5.2, 3.7.10, 3.7.11, and 3.8.4.

These changes are made to align the PTN Technical Specifications, as reasonably practical, with the ISTS. This presentation of the LCO is consistent with the ITS presentation at other sites that utilize shared systems: For example:

Donald C. Cook Nuclear Plant Unit 1 Technical Specifications, LCO 3.8.9, Distribution Systems - Operating, (NRC ADAMS Accession No. ML053050305) and North Anna Power Station Units 1 and 2 ITS 3.8.9, Distribution Systems -

Operating (NRC ADAMS Accession No. ML052990145) for examples of similar alternate ITS presentation which has been previously approved and determined acceptable. This change is designated as more restrictive because additional LCO requirements are being applied in the ITS than were applied in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.3.1 requires, in part, that the following electrical busses*

shall be energized and lists the specific AC buses, 120 Volt AC Vital Panels and 125 Volt DC buses required to be energized. ITS LCO 3.8.9 requires electrical power distribution subsystems shall be OPERABLE but does not list specific electrical buses and panels. This changes the CTS by moving the specific names of the buses and panels, the associated nominal voltages (i.e., 4160 V, 480 V, 125 V, and 120 V), and associated footnotes from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.9 retains the requirement for the required distribution buses and panels to be OPERABLE. In addition, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. The Technical Specification Bases Control Program in Chapter 5 controls changes to the Bases, requiring an evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

Turkey Point Unit 3 and Unit 4 Page 3 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.3.1 requires that electrical busses* shall be energized in the specified manner with the tie breakers open between redundant busses within the unit** and between the busses of Units 3 and 4. CTS 3.8.3.1 Footnote ** states that with the opposite unit in MODE 5, 6, or defueled, its 480-Volt Load Center can be cross-tied under conditions specified in Specification 3.8.3.2.a. ITS LCO 3.8.9 requires the applicable electrical power distribution subsystems to be OPERABLE and ITS Surveillance Requirement (SR) 3.8.9.1 requires the verification of correct breaker alignments and voltage to required AC, DC, and AC vital electrical power distribution subsystems buses and panels. This changes the CTS by moving the procedural detail that the buses must have the tie breakers open between redundant buses from the CTS to the ITS Bases.

The removal of these details for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the required electrical power distribution buses and panels to be OPERABLE and requires the verification of correct breaker alignments and voltage to required AC, DC, and AC vital electrical power distribution buses and panels. In addition, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. The Technical Specification Bases Control Program in Chapter 5 controls changes to the Bases. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA03 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 3.8.3.1 requires two unit trains and one opposite unit train of AC buses to be OPERABLE and lists the required AC buses, including the respective 4160V bus, specific 480V load centers (LCs), and specific 480 V motor control centers (MCCs). The

  • footnote to CTS LCO 3.8.3.1 states that for Motor Control Center buses, vital section only applies. CTS 3.8.3.1, Action a, provides an exception to the condition where one of the required trains of emergency busses are not fully energized. The exception states, "except for the required LC's and MCC's associated with the opposite unit." CTS 3.8.3.1, Action b, provides the required actions for the condition with any of the required LCs and/or MCCs associated with the opposite unit inoperable. The required actions stated in Action b is to restore the inoperable LC or MCC to OPERABLE status in accordance with Table 3.8-1 or Table 3.8-2, as applicable, or shut the unit down. CTS Tables 3.8-1 and 3.8-2 provide specific allowable outage times (AOTs) for opposite unit inoperable LCs or MCCs based on required LC and MCCs. ITS LCO 3.8.9 requires two unit AC electrical power distribution trains and the required opposite unit AC electrical power distribution train(s) that support equipment required by LCO 3.5.2, ECCS -

Operating, LCO 3.7.10, Control Room Emergency Ventilation System Turkey Point Unit 3 and Unit 4 Page 4 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING (CREVS), LCO 3.7.11, Control Room Emergency Air Temperature Control System (CREATCS)," and LCO 3.8.4, DC Sources - Operating, to be OPERABLE. ITS LCO 3.8.9 does not specify specific LCs and MCCs or specific actions for the opposite unit LCs and MCCs. This changes the CTS by relocating the unit MCCs and opposite unit LCs and MCCs and associated actions to the Technical Requirements Manual (TRM). This change also relocates the detail that the requirements only apply to the vital section of the MCCs.

The purpose of the applicable CTS actions is to ensure appropriate compensatory actions are taken in the event an LC or MCC is inoperable that impacts equipment required for the opposite unit (e.g., loss of power to the EDG auxiliary equipment required for an EDG). Based on the number of safety significant electrical loads associated with the AC electrical power distribution trains, the Technical Specification actions limit the time for continued operation to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The intent of the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> AOT associated with the loss of an AC electrical power distribution train is to limit the time an AC bus is inoperable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected AC bus, to the actions associated with taking the unit to shutdown within this time limit, and
b. The potential for an event in conjunction with a single failure of a redundant component in a train with AC power.

MCCs have a smaller number of safety significant electrical loads than 480 V LCs and 4160 V buses. Likewise, LCs associated with the opposite unit have a smaller number of required safety significant electrical loads than the unit 480 V LCs and 4160 V buses. Therefore, the loss of these MCCs and the opposite unit LCs does not result in the same synergistic effect as losing power to an entire unit AC electrical power distribution train (e.g., loss of a unit 4160 V bus).

Opposite unit LCs and MCCs with AOTs of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or in accordance with the Risk Informed Completion Time Program are associated with AC buses that supply power to the 125 VDC battery chargers. LCs and MCCs with AOTs of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program are associated with opposite unit LCs that supply power to auxiliary support equipment for required EDGs and only if the opposite unit EDG is required to meet the unit AC Sources - Operating requirements. The removal of these details for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the required electrical power distribution trains to be OPERABLE and requires the verification of correct breaker alignments and voltage to required AC, DC, and AC vital electrical power distribution buses and panels. Additionally, LCO requirements are retained for each Technical Specification required system, subsystem, train, component, or device powered from these LCs and MCCs. For a required system, subsystem, train, component, or device to be OPERABLE, it must have normal or emergency electrical power as define in Section 1.1, Definitions, Turkey Point Unit 3 and Unit 4 Page 5 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING which requires the associated LC and MCC to be energized. Individual LCs and MCCs, which help comprise the AC and DC distribution systems, that are not listed in ITS Bases Table B 3.8.9-1 will not result in a complete loss of a redundant safety function necessary to shut down the reactor and maintain it in a safe condition. Therefore, should one or more of these buses become inoperable due to a failure not affecting the OPERABILITY of a bus listed in ITS Bases Table B 3.8.9-1 for Unit 3 and Table B 3.8.9-2 for Unit 4 (e.g., a breaker R2 supplying a single distribution panel fails open), the individual loads on the bus would be declared inoperable, and the appropriate Conditions and Required Actions of the LCOs governing the individual loads would be entered. As a result of the relocation of the opposite unit LCs, and MCCs, the Risk Informed Completion Time (RICT) stated in Footnote ** and Footnote a of CTS R2 Tables 3.8-1 and 3.8-2 are deleted. RICT will continue to be applied, as applicable, to individual loads in accordance with the ACTIONS associated with the supported system LCOs. Also, this change is acceptable because this type of procedural detail will be adequately controlled in the TRM. Changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because specific AC Electrical Power Distribution System LCs and MCCs and associated ACTIONS are being removed from the Technical Specifications.

LA04 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.3.1.l, m, n, and o, states, in part, that each 125 Volt D.C. Bus (3D01, 3D23, 4D01, and 4D23) must be energized from an associated battery charger and from its associated Battery Bank (3A, 3B, 4B, or 4A, respectively) or spare battery bank D-52. ITS LCO 3.8.9 states, "The following electrical power distribution trains and subsystems shall be OPERABLE: . . . ." R2 ITS LCO 3.8.9 item c. includes in ITS LCO 3.8.9 OPERABILITY requirements four DC electrical power distribution trains. This changes the CTS by moving the specific detail of what constitutes an OPERABLE DC electrical power distribution train from the CTS to the ITS Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.9 retains the requirement for the required DC electrical power distribution trains to be OPERABLE. In addition, this change is acceptable because the removed information will be adequately R2 controlled in the ITS Bases. The Technical Specification Bases Control Program in Chapter 5 controls changes to the Bases, requiring an evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS LCO 3.8.3.1 requires the 120 VAC vital panels to be energized from the associated inverters connected to a DC bus. CTS 3.8.3.1, ACTION c, states, in part, that with one AC vital panel Turkey Point Unit 3 and Unit 4 Page 6 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING either not energized from its associated inverter, or with the inverter not connected to its associated DC bus to reenergize the AC vital panel. There is no other LCO requirement for the inverters to be OPERABLE or actions if inoperable. In the ITS, the inverters are in a separate Specification (ITS 3.8.7 for MODES 1, 2, 3, and 4 or ITS 3.8.8 for the MODES 5 and 6, and during movement of irradiated fuel assemblies). The 120 VAC vital panels are in separate Specifications under the same conditions (ITS 3.8.9 and ITS 3.8.10, respectively). CTS 3.8.3.1, Action c, requires that when a 120 Volt AC vital panel is either not energized from its associated inverter, or with the inverter not connected to its associated DC bus to 1) reenergize the AC vital panel within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or in accordance with the Risk Informed Completion Time Program, and

2) reenergize the AC vital panel from an inverter connected to its associated DC bus within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or in accordance with the Risk Informed Completion Time Program. ITS LCO 3.8.9, in part, requires four unit AC vital electrical power distribution subsystems and required opposite unit AC vital electrical power distribution subsystems to support high head safety injection subsystem, CREVS, CREATCS, and EDG automatic load sequencers. ITS 3.8.9 ACTION B requires, with one or more AC vital electrical power distribution subsystems inoperable, to restore the AC vital electrical power distribution subsystem(s) to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or in accordance with the Risk Informed Completion Time Program. ITS 3.8.7 ACTION A requires, with one required inverter inoperable, to restore the inverter to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or in accordance with the Risk Informed Completion Time Program. This changes the CTS by allowing the 120 VAC vital buses to be considered OPERABLE when powered from a source other than the inverter connected to a DC bus.

The purpose of CTS LCO 3.8.3.1 is, in part, to provide requirements for ensuring the 120 VAC vital panels are energized so they can perform their intended safety function. ITS LCO 3.8.9 specifies that the required AC vital electrical power distribution subsystems are to be OPERABLE. Consistent with the definition of OPERABLE specified in Section 1.1, Definitions, a 120 VAC vital panel is considered OPERABLE provided it is energized from its normal or emergency power source. The requirement for an inverter to be powered from its associated DC bus is provided in ITS LCO 3.8.7 and LCO 3.8.8. For the 120 VAC vital panels to be OPERABLE, the panels only need to be powered from a qualified source (i.e., each of the allowed sources can carry the required loads on the associated vital bus). The change is acceptable since the change is consistent with the definition of OPERABILITY and the ability of the 120 VAC vital panels to support the dependent components and systems is not dependent of the specific source of the power provided the power source is a qualified electrical power source. The 120 VAC vital panels can perform their intended safety function provided they are energized from either an inverter via inverted DC voltage, an inverter via the internal static switch, or the constant voltage transformer via the maintenance bypass switch. These sources are capable of providing the necessary voltage, frequency, and capacity to the associated 120 VAC vital panels. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

Turkey Point Unit 3 and Unit 4 Page 7 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING L02 (Category 1 - Relaxation of LCO Requirements) CTS LCO 3.8.3.1 requires the 125 VDC buses to be energized from an associated battery charger and from a battery bank or the spare battery bank D-52. CTS 3.8.3.1, Action d, requires that with one DC bus not energized from its associated battery bank or associated charger, reenergize the DC bus from its associated battery bank within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s*

or in accordance with the Risk Informed Completion Time Program. The

  • footnote allows extension of the action time from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, in part, when the opposite unit is in MODE 5, 6, or defueled. ITS LCO 3.8.9 requires, in part, four DC electrical power distribution trains to be OPERABLE. ITS 3.8.9, ACTIONS C and D, require, with one or more DC trains inoperable (i.e., not energized) to restore the DC electrical buses to OPERABLE status (i.e.,

reenergized) within the same required Completion Time as the CTS actions.

However, the action does not explicitly require the DC bus to be reenergized from its associated battery bank. This changes the CTS by allowing the LCO and ACTIONS associated with the 125 VDC buses to be met when powered from either its associated battery, spare battery, or a qualified battery charger (normal or backup battery charger).

The purpose of CTS LCO 3.8.3.1 is, in part, to provide requirements for ensuring the 125 VDC buses are energized so they can perform their intended safety function. Consistent with the definition of OPERABLE specified in Section 1.1, Definitions, a 125 VDC bus is considered OPERABLE provided it is energized from its normal or emergency power source. There are two methods of reenergization to restore the DC trains to OPERABLE status from either; 1) a qualified battery charger (normal or backup charger), or 2) the associated battery bank or installed spare battery bank. The change is acceptable since the change is consistent with the definition of OPERABILITY and the ability of the 125 VDC electrical power distribution trains to support the dependent components and systems is not dependent of the specific source of the power, provided the power source is a qualified electrical power source (battery or battery charger). In addition, requirements associated with the batteries and chargers continue to be maintained in ITS 3.8.4, DC Sources - Operating, to ensure any degradation associated with the DC sources supplying the 125 VDC buses is appropriately addressed, and necessary actions performed. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L03 (Category 4 - Relaxation of Required Action) CTS 3.8.3.1 ACTION a, in part, states "With one of the required trains of A.C. emergency busses not fully energized..." CTS 3.8.3.1, ACTION c, in part, states "With one A.C. vital panel either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus..." CTS 3.8.3.1, ACTION d, in part, states "With one D.C. bus not energized from its associated battery bank or associated charger..." ITS LCO 3.8.9, Condition A, states "One or more required AC electrical power distribution trains inoperable." ITS LCO 3.8.9, Condition B, states "One or more AC vital electrical power distribution subsystems inoperable." ITS LCO 3.8.9, Condition C, states "One or more opposite unit DC electrical power distribution trains inoperable." ITS LCO 3.8.9 Condition D states "One or more DC electrical power distribution trains inoperable for reasons other than Condition C." ITS LCO 3.8.9, Condition G, provides the appropriate Turkey Point Unit 3 and Unit 4 Page 8 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Required Action if two or more electrical power distribution trains or subsystems become inoperable and a loss of safety function occurs. This changes the CTS by allowing more than one electrical power distribution train or subsystem to be inoperable provided a loss of safety function has not occurred.

The purpose of ITS 3.8.9 Conditions A, B, C, and D, is to ensure remedial action is provided to ensure required safety features have electrical power to perform the specified safety function. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Conditions, considering the OPERABLE status of the redundant systems or features to ensure safety function is maintained. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a design basis accident (DBA) occurring during the repair period.

The electrical power distribution trains are composed of the 4160 VAC emergency buses, 480 VAC emergency bus load centers, 480 VAC motor control centers, 120 VAC vital panels, and 125 VDC buses. Although more than one of the trains, subsystems, and components may be inoperable, the Engineered Safety Feature (ESF) functions may be able to provide the specified safety functions with the remaining OPERABLE electrical buses. ITS 3.8.9 ACTION G provides the Required Action if two or more electrical power distribution trains or subsystems become inoperable and a loss of safety function occurs. Required Action G.1 requires an entry into LCO 3.0.3 immediately. The proposed actions are consistent with the ISTS and provide acceptable remedial actions pursuant to 10 CFR 50.36(c)(2)(i). This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L04 (Category 4 - Relaxation of Required Action) CTS 3.8.3.1, ACTION a, in part, require, if the associated required actions and completion times are not met, to be in in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. ITS 3.8.9, ACTION E, requires, with the Required Action and associated Completion Time of Condition A, B, C, or D not met, to be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by requiring a less restrictive end state in the required actions, MODE 4 (HOT SHUTDOWN) instead of MODE 5 (COLD SHUTDOWN).

The purpose of the CTS 3.8.3.1 ACTIONS is to limit the time the unit can remain operating with different combinations of AC emergency buses. Once these limits are exceeded, ACTION E is entered to provide a reasonable time to place the unit is a safe condition. End states are usually defined based on placing the unit into a MODE or condition in which the Technical Specification LCO is not applicable. MODE 5 is the current end state for LCOs that are applicable in MODES 1 through 4. This change is acceptable because the risk of the transition from MODE 1 to MODES 4 or 5 depends on the availability of AC sources and the ability to remove decay heat such that remaining in MODE 4 may be safer. During the realignment from MODE 4 to MODE 5, there is an increased potential for loss of shutdown cooling and loss of inventory events.

Turkey Point Unit 3 and Unit 4 Page 9 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING Decay heat removal following a loss-of-offsite power event in MODE 5 is dependent on AC power for shutdown cooling whereas, in MODE 4, the turbine driven auxiliary feedwater (AFW) pump will be available. Therefore, transitioning to MODE 5 is not always the appropriate end state from a risk perspective.

Thus, for specific TS conditions, Westinghouse Topical Report WCAP-16294-A, Revision 1 (ADAMS Accession No. ML103430249) justifies MODE 4 as an acceptable alternate end state to Mode 5. The proposed change to the Technical Specifications will allow time to perform short-duration repairs, which currently necessitate exiting the original mode of applicability. The MODE 4 TS end state is applied, and risk is assessed and managed in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." Modified end states are limited to conditions where: (1) entry into the shutdown mode is for a short interval, (2) entry is initiated by inoperability of a single train of equipment or a restriction on a plant operational parameter, unless otherwise stated in the applicable TS, and (3) the primary purpose is to correct the initiating condition and return to power operation as soon as is practical. This proposed change is consistent with NRC approved TSTF-432-A, Revision 1 (ADAMS Accession No. ML103360003), noticed for availability by the NRC in the Federal Register (77 FR 27814) on May 11, 2012. The NRC's approval of WCAP-16294-A included four limitations and conditions on its use as identified in Section 4.0 of the NRC Safety Evaluation associated with WCAP-16294-A.

Implementation of these stipulations were addressed in the Bases of TSTF-432-A. Florida Power & Light implemented these limitations and conditions at PTN in the adoption of the associated TSTF-432-A Bases. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L05 (Category 4 - Relaxation of Required Action) CTS 3.8.3.1, ACTION c and ACTION d, in part, require, if the associated Required Action and Completion Time are not met, to be in in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. ITS 3.8.9, ACTION F requires, with the Required Action and associated Completion Time of Condition A, B, C, or D not met, to be in MODE 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 in 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

This changes the CTS by requiring a less restrictive end state in the required actions, MODE 4 (HOT SHUTDOWN) instead of MODE 5 (COLD SHUTDOWN).

The purpose of the CTS 3.8.3.1 ACTIONS is to limit the time the unit can remain operating with different combinations of inoperable buses or panels.

CTS 3.8.3.1, ACTION c, is associated with inoperable 120 VAC vital panels and CTS 3.8.3.1, ACTION d, is associated with inoperable 125 VDC buses.

Similarly, ITS 3.8.9, Condition B, is associated with inoperable 120 VAC vital panels while ITS 3.8.9, Conditions C and D, are associated with inoperable 125 VDC buses. Once the Required Action Completion Times for one or more inoperable AC, DC, or AC vital electrical power distribution train or subsystem are exceeded, ACTION F is entered to provide a reasonable time to place the unit in a safe condition and considers the condition when a dual unit shutdown is required. End states are usually defined based on placing the unit into a MODE or condition in which the Technical Specification LCO is not applicable. MODE 5 is the current end state for LCOs that are applicable in MODES 1 through 4. This Turkey Point Unit 3 and Unit 4 Page 10 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING change is acceptable because the risk of the transition from MODE 1 to MODES 4 or 5 depends on the availability of AC sources and the ability to remove decay heat such that remaining in MODE 4 may be safer. During the realignment from MODE 4 to MODE 5, there is an increased potential for loss of shutdown cooling and loss of inventory events. Decay heat removal following a loss-of-offsite power event in MODE 5 is dependent on AC power for shutdown cooling whereas, in MODE 4, the turbine driven AFW pump will be available. Therefore, transitioning to MODE 5 is not always the appropriate end state from a risk perspective. Thus, for specific TS conditions, Westinghouse Topical Report WCAP-16294-A, Revision 1 (ADAMS Accession No. ML103430249) justifies MODE 4 as an acceptable alternate end state to Mode 5. The proposed change to the Technical Specifications will allow time to perform short-duration repairs, which currently necessitate exiting the original mode of applicability. The MODE 4 TS end state is applied, and risk is assessed and managed in accordance with 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." Modified end states are limited to conditions where: (1) entry into the shutdown mode is for a short interval, (2) entry is initiated by inoperability of a single train of equipment or a restriction on a plant operational parameter, unless otherwise stated in the applicable TS, and (3) the primary purpose is to correct the initiating condition and return to power operation as soon as is practical. This proposed change is consistent with NRC approved TSTF-432-A, Revision 1 (ADAMS Accession No. ML103360003),

noticed for availability by the NRC in the Federal Register (77 FR 27814) on May 11, 2012. The NRC's approval of WCAP-16294-A included four limitations and conditions on its use as identified in Section 4.0 of the NRC Safety Evaluation associated with WCAP-16294-A. Implementation of these stipulations were addressed in the Bases of TSTF-432-A. Florida Power & Light implemented these limitations and conditions at PTN in the adoption of the associated TSTF-432-A Bases. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L06 (Category 4 - Relaxation of Required Action) CTS LCO 3.8.3.1 Action d, with one DC bus not energized from its associated battery bank or associated charger, requires action to reenergize the DC bus from its associated battery bank within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s* or in accordance with the Risk Informed Completion Time Program. The

  • footnote allows extension of the action time from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the opposite unit is in MODE 5, 6, or defueled and each of the remaining required battery chargers is capable of being powered from its associated diesel generators. ITS 3.8.9, ACTION C, requires, with one or more opposite DC trains inoperable (i.e., not energized), to restore the DC electrical power distribution train(s) to OPERABLE status (i.e., reenergized) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or in accordance with the Risk Informed Completion Time Program. The ITS ACTION is only applicable when the opposite unit is in MODE 5 or 6, or defueled. This changes the CTS by not explicitly requiring the remaining battery chargers to be capable of being powered from its associated diesel generator(s) to apply the extended allowable outage time (AOT) of a DC bus.

The purpose of

  • footnote associated with CTS LCO 3.8.3.1 Action d is to allow additional time to perform repairs to an inoperable 125 VDC bus if only one unit Turkey Point Unit 3 and Unit 4 Page 11 of 12

DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING is operating, and all the remaining battery chargers are capable of being powered from their associated diesel generators. Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The ITS Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the repair period. CTS 3.8.2.1 (ITS 3.8.4) provides appropriate action requirements when one or more required battery chargers are inoperable, and CTS 3.8.1.1 (ITS 3.8.1) provides sufficient action requirements when an EDG is inoperable concurrent with a redundant required battery charger inoperable. Therefore, it is unnecessary to require a verification that the remaining battery chargers be capable of being powered from its associated diesel generator(s) to apply the extended AOT from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when an opposite unit 125 VDC bus is inoperable. The Required Actions associated with ITS 3.8.1 and 3.8.4 ensure risk associated with the condition of an inoperable battery charger concurrent with an inoperable EDG associated with a redundant required battery charger is minimize. This change is designated as less restrictive because less stringent requirements associated with an action are being applied in the ITS than were applied in the CTS.

Turkey Point Unit 3 and Unit 4 Page 12 of 12

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating The following trains and 3.8.1.1.b.1)f),

3.8.1.1.b.2)d), LCO 3.8.9 Train A and Train B AC, DC, and AC vital bus electrical power distribution 1

3.8.3.1 subsystems shall be OPERABLE.

INSERT 1 Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME required 2 3.8.3.1 A. One or more AC A.1 --------------NOTE--------------

Action a electrical power Enter applicable Conditions distribution subsystems and Required Actions of 1 inoperable. trains LCO 3.8.4, "DC Sources -

Operating," for DC trains 1 made inoperable by power inoperable power distribution subsystems. 1 trains Restore AC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> distribution subsystem(s) to 1 OPERABLE status. train [OR 3 In accordance with the Risk Informed Completion Time Program] 3 3.8.3.1 2 Action c. B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> buses inoperable. subsystem(s) to 1 electrical power OPERABLE status. [OR 3 distribution subsystems electrical power distribution subsystem(s) In accordance with the Risk Informed Completion Time Program] 3 INSERT 2 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.9-1 Rev. 5.0 1

CTS 4

ITS 3.8.9 INSERT 1 3.8.3.1.a a. Two unit AC electrical power distribution trains, 3.8.3.1.b 3.8.3.1.c b. Required opposite unit AC electrical power distribution train(s) to DOC M01 support equipment required by LCO 3.5.2, ECCS - Operating, LCO 3.7.10, Control Room Emergency Ventilation System (CREVS), LCO 3.7.11, Control Room Emergency Air Temperature Control System (CREATCS)," and LCO 3.8.4, DC Sources - Operating, 3.8.3.1.l, m, n, o c. Four DC electrical power distribution trains, 3.8.3.1.d, f, h, j for Unit 3 d. Four unit AC vital electrical power distribution subsystems, and 3.8.3.1.e, g, i, k for Unit 4 3.8.3.1.d, f, h, j for Unit 4

e. Required opposite unit AC vital electrical power distribution 3.8.3.1.e, g, i, k for Unit 3 subsystems to support LCO 3.5.2, LCO 3.7.10, LCO 3.7.11, and LCO 3.8.1, AC Sources - Operating.

2 INSERT 2 C. -------------NOTE----------- C.1 Restore DC electrical 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 3.8.3.1 Not applicable when power distribution trains to Action d.

opposite unit is in OPERABLE status. OR DOC L06 MODE 1, 2, 3 or 4.

In accordance with One or more opposite the Risk Informed unit DC electrical power Completion Time distribution trains Program.

inoperable.

Insert Page 3.8.9-1

CTS Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D D 3.8.3.1 C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 5 Action d.

electrical power power distribution distribution subsystems trains subsystem(s) to [OR 1 3 inoperable. trains OPERABLE status.

for reasons other than Condition C In accordance with the Risk Informed

NOTE--------------

Not applicable when a dual Completion Time unit shutdown is required. Program] 3 E E 6

3.8.3.1 D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 5 Action a associated Completion Time not met. AND 7 of Condition A, B, C, E or D D.2 --------------NOTE-------------- 5 LCO 3.0.4.a is not applicable when entering MODE 4.

DOC L04 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> INSERT 3 G G E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately 5 DOC L03 power distribution trains or subsystems inoperable 1 that result in a loss of safety function.

Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.9-2 Rev. 5.0 1

CTS ITS 3.8.9 2

INSERT 3 3.8.3.1 F. -----------NOTE------------ F.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action c.,

3.8.3.1 Only applicable when a Action d. dual unit shutdown is AND required.

F.2 --------------NOTE--------------

LCO 3.0.4.a is not Required Action and applicable when entering DOC L05 associated Completion MODE 4.

Time of Condition A, B, -------------------------------------

C, or D not met.

Be in MODE 4. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> Insert Page 3.8.9-2

CTS Distribution Systems - Operating 3.8.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.3.1 SR 3.8.9.1 Verify correct breaker alignments and voltage to [ 7 days

[required] AC, DC, and AC vital bus electrical power 3 distribution subsystems. DC OR 1 trains, and required AC vital electrical power distribution In accordance with the Surveillance Frequency Control Program ] 3 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.9-3 Rev. 5.0 1

JUSTIFICATION FOR DEVIATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. Changes are made to the ISTS to reflect the interaction between an operating unit's electrical distribution subsystem and those credited features needing support from the opposite unit's associated electrical distribution subsystem. Subsequent Conditions have been relabeled.
3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
4. The ISTS is based on a single plant design with two redundant trains/subsystems.

Due to the shared systems between the units, the current PTN Specification is presented on facility basis instead of a unit basis. Therefore, changes are made (additions, deletions, and/or changes) to the ISTS presentation that reflect the plant-specific multi-unit and shared systems design on a unit basis. The changes do not represent a change to the plant design or safety analysis basis. These changes are consistent with the ITS presentation of other multi-unit sites with shared systems and made to align the PTN Technical Specifications, as reasonably practical, with the ISTS. Refer to Donald C. Cook Nuclear Plant Unit 1 Technical Specifications, LCO 3.8.9, Distribution Systems - Operating, (NRC ADAMS Accession No. ML053050305) and North Anna Power Station Units 1 and 2 ITS 3.8.9, Distribution Systems - Operating (NRC ADAMS Accession No. ML052990145) for examples of this alternate ITS presentation which have been previously approved and determined acceptable.

5. Changes have been made to add or delete Actions, the subsequent Actions and Required Actions have been renumbered to reflect the additions and deletions.
6. Changes have been made to address Actions that apply to both units simultaneously. PTNs licensing bases allows 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in MODE 3 if the Required Actions require the shut down of one Unit. If the Required Actions require the shut down of both Units, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed to reach MODE 3. The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allows for a sequential shut down of one unit in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and the second unit in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for the shut down of each unit.
7. Changes have been made to incorporate other Improved Standard Technical Specification (ISTS) changes in the PTN ITS.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Distribution Systems - Operating B 3.8.9 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.9 Distribution Systems - Operating BASES BACKGROUND The onsite Class 1E AC, DC, and AC vital bus electrical power distribution systems are divided by train into [two] redundant and independent AC, DC, and AC vital bus electrical power distribution buses and panels subsystems. Specific electrical distribution subsystems are shared 2 R2 INSERT 1 between the units to support required loads.

The AC electrical power subsystem for each train consists of a primary Engineered Safety Feature (ESF) 4.16 kV bus and secondary [480 and 120] V buses, distribution panels, motor control centers and load centers.

Each [4.16 kV ESF bus] has at least [one separate and independent offsite source of power] as well as a dedicated onsite diesel generator (DG) source. Each [4.16 kV ESF bus] is normally connected to a preferred offsite source. After a loss of the preferred offsite power source to a 4.16 kV ESF bus, a transfer to the alternate offsite source is accomplished by utilizing a time delayed bus undervoltage relay. If all offsite sources are unavailable, the onsite emergency DG supplies power to the 4.16 kV ESF bus. Control power for the 4.16 kV breakers is supplied from the Class 1E batteries. Additional description of this system may be found in the Bases for LCO 3.8.1, "AC Sources -

Operating," and the Bases for LCO 3.8.4, "DC Sources - Operating."

1 The secondary AC electrical power distribution subsystem for each train includes the safety related buses, load centers, motor control centers, and distribution panels shown in Table B 3.8.9-1.

The 120 VAC vital buses are arranged in two load groups per train and are normally powered from the inverters. The alternate power supply for the vital buses are Class 1E constant voltage source transformers powered from the same train as the associated inverter, and its use is governed by LCO 3.8.7, "Inverters - Operating." Each constant voltage source transformer is powered from a Class 1E AC bus.

The DC electrical power distribution subsystem consists of [125] V bus(es) and distribution panel(s).

The list of all required DC and vital AC distribution buses [and panels] is 2 1

presented in Table B 3.8.9-1.

for Unit 3 and Table B 3.8.9-2 for Unit 4 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-1 Rev. 5.0 1

ITS 3.8.9 1

INSERT 1 The Class 1E AC Electrical Power Distribution System consists of 4.16 kV buses, 480V load center (LC) buses and motor control center (MCC) buses, 120V Instrument (Vital) AC subsystems, and 125V DC buses. For each unit there are three safety related 4.16 kV switchgear, two of which are fed separately from the double secondary windings of its unit auxiliary transformer under normal operating conditions. At any time when power from the auxiliary transformer is not available, these buses are energized from the double ("X" and "Y")

secondary windings of the startup transformer.

Two of the 4.16 kV switchgear, labeled as "A" and "B", provide power to the A and B trains of Engineered Safety Features (ESF), respectively, in each unit. The third safety related 4.16 kV switchgear, labeled as the "D" switchgear, is utilized as a swing bus. The 4.16 kV swing bus can be manually aligned to either the Train A or Train B 4.16 kV bus of its respective unit. An automatic transfer switch provides control power from one of two DC sources to assure control power will always be available for manual alignment of this swing switchgear. Interlocks ensure that the swing switchgear can only be connected to one 4.16 kV bus at a time. When the 4.16 kV swing switchgear is connected to either of the 4.16 kV supply buses, it is considered an extension of that power supply bus.

Chapter 8 of the UFSAR (Ref.1) provides the description of the AC electrical distribution system.

The 480 V LC buses are arranged in the same manner for Units 3 and 4. For each unit there are five safety related 480V LC buses, four of which are energized from different 4.16 kV busses (LCs A and C are fed from Train A and LCs B and D are fed from Train B). This arrangement ensures the availability of equipment associated with a particular function in the event of loss of one 4.16 kV bus. The fifth safety related 480V LC in each unit is a swing LC, which can swing between Train A and B of its associated unit. The swing LC bus can be manually aligned to either train (Train A or Train B) of the respective unit AC Electrical Power Distribution System. These swing LCs are labeled as 3H for Unit 3 and 4H for Unit 4. When the 480 V swing LC is connected to either 480 V supply bus, it is considered to be an extension of that 480 V supply bus. The swing LCs are used to supply shared system and cross-unit loads.

Upon loss of normal power to the swing LC bus, the bus will automatically transfer to the redundant AC electrical power distribution train, if available, to maintain continuity of power to the loads.

The 480 V system includes MCCs powered from the LCs and are arranged in a similar manner for Units 3 and 4. Eight MCCs per unit are powered by safety related LCs with four per unit considered vital and two per unit suppling the emergency diesel generator (EDG) support systems. Three of the eight safety related MCC have a vital and a non-vital section, MCCs A, B, and C. The fourth vital MCC (MCC D) is connected to the unit swing LC, and thus, is considered a swing MCC.

INSERT Page B 3.8.9-1a

ITS 3.8.9 1

INSERT 1 (cont.)

The 120 V Instrument AC System has four sets of equipment for each unit, each set consisting of a 7.5 kVA, 125 V DC/120 V AC inverter, distribution panel, static transfer switch and an associated constant voltage transformer (CVT) for alternate 120 V AC supplied from a vital MCC. Each inverter is normally powered by a separate bus of the DC Electrical Power Distribution System. Upon overload or loss of the inverter AC output, the static switch in the output of the inverter automatically fast transfers to the alternate AC supply via the CVT, if available, to maintain continuity of output power. Four 7.5 kVA, 125 V DC/120 V AC spare inverters are provided to allow maintenance on the normal inverters. One spare inverter is provided for each pair of normal inverters of the same channel. The spare inverters are manually placed in service and can serve as backup to the normal source for each unit. The alternate AC supply is normally aligned with its associated normal inverter but can be aligned to the spare inverter by actuating the alternate source transfer switch. Each spare inverter can be aligned with the CVT associated with the inverter it is replacing. The vital instrumentation load for each unit is distributed on the four buses in such a manner to avoid the complete loss of any particular function with the loss of any single bus.

INSERT Page B 3.8.9-1b

Distribution Systems - Operating B 3.8.9 BASES APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient 2

SAFETY analyses in the FSAR, Chapter [6] (Ref. 1), and in the FSAR, U 2 1 14 ANALYSES Chapter [15] (Ref. 2), assume ESF systems are OPERABLE. The AC, 3

DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution systems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit.

This includes maintaining power distribution systems OPERABLE during accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC electrical power 1 and
b. A worst case single failure.

The distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

buses and panels LCO The required power distribution subsystems listed in Table B 3.8.9-1 1 ensure the availability of AC, DC, and AC vital bus electrical power for the R2 (Unit 3) and Table B 3.8.9-2 (Unit 4) systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. The AC, DC, and AC vital bus electrical power buses and panels distribution subsystems are required to be OPERABLE. 1 Maintaining the Train A and Train B AC, DC, and AC vital bus electrical buses and panels power distribution subsystems OPERABLE ensures that the redundancy 1 incorporated into the design of ESF is not defeated. Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor.

trains OPERABLE AC electrical power distribution subsystems require the 1 associated buses, load centers, motor control centers, and distribution trains panels to be energized to their proper voltages. OPERABLE DC electrical power distribution subsystems require the associated buses and

, spare battery (D52), or distribution panels to be energized to their proper voltage from either the 1 R2 charger (normal or backup) associated battery or charger. OPERABLE vital bus electrical power distribution subsystems require the associated buses to be energized to their proper voltage from the associated [inverter via inverted DC voltage, via the static switch inverter using internal AC source, or Class 1E constant voltage 2 transformer].

via the maintenance bypass switch INSERT 2 1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-2 Rev. 5.0 1

ITS 3.8.9 1

INSERT 2 Based on the number of safety significant electrical loads associated with each bus listed in Tables B 3.8.9-1 (Unit 3) and B 3.8.9-2 (Unit 4), if one or more of the buses becomes inoperable, entry into the appropriate ACTIONS of LCO 3.8.9 is required. Some buses, such as distribution panels, motor control centers, and load centers, which help comprise the AC and DC distribution systems, are not listed in Table B 3.8.9-1 (Unit 3) or Table B 3.8.9-2 (Unit 4).

The loss of electrical loads associated with these buses may not result in a complete loss of a redundant safety function necessary to shut down the reactor and maintain it in a safe condition.

Therefore, should one or more of these buses become inoperable due to a failure not affecting the OPERABILITY of a bus listed in Table B 3.8.9-1 (Unit 3) or Table B 3.8.9-2 (Unit 4) (e.g., a breaker supplying a single distribution panel fails open), the individual loads on the bus would be declared inoperable, and the appropriate Conditions and Required Actions of the LCOs governing the individual loads would be entered. However, if one or more of these buses is inoperable due to a failure also affecting the OPERABILITY of a bus listed in Table B 3.8.9-1 (Unit 3) or Table B 3.8.9-2 (Unit 4) (e.g., loss of 4.16 kV essential bus, which results in de-energization of all buses powered from the 4.16 kV essential bus), then the Conditions and Required Actions of the LCO 3.8.9 must be entered.

INSERT Page B 3.8.9-2

Distribution Systems - Operating B 3.8.9 BASES LCO (continued)

In addition, tie breakers between redundant safety related AC, DC, and AC vital bus power distribution subsystems, if they exist, must be open.

This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, that could cause the failure of a redundant subsystem and a loss of essential safety function(s). If any tie breakers are closed, the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related redundant electrical power distribution subsystems. It does not, however, preclude redundant Class 1E 4.16 kV INSERT 2A buses from being powered from the same offsite circuit.

APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and
b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Electrical power distribution subsystem requirements for MODES 5 and 6 are covered in the Bases for LCO 3.8.10, "Distribution Systems -

Shutdown."

ACTIONS A.1 With one or more Train A and B required AC buses, load centers, motor control centers, or distribution panels (except AC vital buses), in one train 1 inoperable and a loss of function has not occurred, the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> [or in accordance with 2

the Risk Informed Completion Time Program].

Condition A worst scenario is one train without AC power (i.e., no offsite EDG power to the train and the associated DG inoperable). In this Condition, 1 the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operator's attention be focused on minimizing the potential for loss of power to the remaining train by Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-3 Rev. 5.0 1

ITS 3.8.9 INSERT 2A Redundant required features (i.e., redundant trains, subsystems, or components required by the R2 supported system Specifications) may be supplied from the same AC electrical power distribution train via a swing bus (i.e., swing LC or associated swing MCC) and not violate electrical separate criteria provided automatic transfer capability is available to the other AC electrical power distribution train. If the automatic transfer capability is not available when redundant required features are powered from the same AC electrical power distribution train, the swing bus and associated safety related loads are inoperable.

Also, when the swing LC transfers between supply buses (manual or automatic) the bus will R2 momentarily de-energize. Because this is the specified manner of operation the momentary de-energization is not considered an inoperable AC bus.

INSERT Page B 3.8.9-3

Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued) stabilizing the unit, and on restoring power to the affected train. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit before requiring a unit shutdown in this Condition is acceptable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to shutdown within this time limit and
b. The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

Required Action A.1 is modified by a Note that requires the applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources - Operating,"

to be entered for DC trains made inoperable by inoperable power distribution subsystems. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This Note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

B.1 With one or more AC vital buses inoperable, and a loss of function has not yet occurred, the remaining OPERABLE AC vital buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition. Overall reliability is reduced, however, since an additional single failure could result in the minimum [required] ESF functions not being supported. Therefore, the 2 or spare required AC vital bus must be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by powering the bus from the associated [inverter via inverted via the static switch 1 DC, inverter using internal AC source, or Class 1E constant voltage via the maintenance bypass switch transformer]. [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.]

Condition B represents one or more AC vital buses without power; potentially both the DC source and the associated AC source are nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all noninterruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining vital buses and restoring power to the affected vital bus.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-4 Rev. 5.0 1

Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for the vast majority of components that are without adequate vital AC power.

Taking exception to LCO 3.0.2 for components without adequate vital AC power, that would have the Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> if declared inoperable, is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable operations to continue,
b. The potential for decreased safety by requiring entry into numerous Applicable Conditions and Required Actions for components without adequate vital AC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train, and
c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time takes into account the importance to safety of restoring the AC vital bus to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low INSERT 3 probability of a DBA occurring during this period. 1 D

C.1 for reasons other 3 trains than Condition C With one or more DC buses or distribution panels inoperable, and a loss 1 trains of function has not yet occurred, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety 1 functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical train power distribution subsystem could result in the minimum required ESF functions not being supported. Therefore, the [required] DC buses and 2 1

, spare battery, or distribution panels must be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> qualified charger (normal or backup) by powering the bus from the associated battery or charger.

[Alternatively, a Completion Time can be determined in accordance with 2 the Risk Informed Completion Time Program.]

D 3 1 Condition C represents one or more DC buses or distribution panels without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-5 Rev. 5.0 1

ITS 3.8.9 1

INSERT 3 C.1 With one or more opposite unit DC buses inoperable, and a loss of function has not yet occurred, the remaining DC electrical power distribution trains are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in a remaining DC electrical power distribution train could result in the minimum required ESF functions not being supported. The Completion Time for the DC bus is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in order to allow for required battery maintenance without requiring both units to be shutdown.

Therefore, the DC buses and distribution panels must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by powering the bus from the associated battery, spare battery, or qualified charger (normal or backup charger). Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

The Condition is modified by a Note limiting its use to when the opposite unit is not in operation (i.e., MODE 5 or 6, or defueled) to further reduce overall plant risk when a required DC bus is inoperable. If a required opposite unit DC bus is inoperable with both units in MODE 1, 2, 3, or 4, Condition D applies.

INSERT Page B 3.8.9-5

Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued) power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for the vast majority of components that would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue,
b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train, and
c. The potential for an event in conjunction with a single failure of a redundant component.

4 The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3). 1 E

D.1 and D.2 3 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant 5

risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 1 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-6 Rev. 5.0 1

Distribution Systems - Operating B 3.8.9 BASES ACTIONS (continued)

E Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is 3 not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

INSERT 4 G

E.1 3 G

Condition E corresponds to a level of degradation in the electrical power 3 bus and panel distribution system that causes a required safety function to be lost.

When more than one inoperable electrical power distribution subsystem 1 results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.9.1 REQUIREMENTS This Surveillance verifies that the [required] AC, DC, and AC vital bus 2 buses and panels electrical power distribution systems are functioning properly, with the 1 correct circuit breaker alignment. The correct breaker alignment ensures trains the appropriate separation and independence of the electrical divisions is 1 maintained, and the appropriate voltage is available to each required bus.

and panels The verification of proper voltage availability on the buses ensures that 1 the required voltage is readily available for motive as well as control and panels functions for critical system loads connected to these buses. [ The 7 day 1 Frequency takes into account the redundant capability of the AC, DC, and AC vital bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to 2 subsystem malfunctions.

OR Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-7 Rev. 5.0 1

ITS 3.8.9 1

INSERT 4 F.1 and F.2 If the inoperable electrical power distribution train cannot be restored to OPERABLE status within the required Completion Time and a dual unit shutdown is required, the units must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the units are shutdown consecutively such that both units are brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

Condition F is modified a Note. The Note states that the Condition only applies when a dual unit shutdown is required. To achieve a consecutive unit shutdown, the first unit should be in MODE 3 and MODE 4 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, respectively, to allow time for the second unit to reach MODE 3 and MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, respectively. This allows for the orderly shutdown of one unit at a time and not jeopardize the stability of the electrical grid by imposing a simultaneous dual unit shutdown.

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 5). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, a steam turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action F.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are reasonable, based on operating experience, to reach the required conditions for two units from full power conditions in an orderly manner and without challenging plant systems.

INSERT Page B 3.8.9-7

Distribution Systems - Operating B 3.8.9 BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

2 U 1. UFSAR Chapter 8 REFERENCES 1. FSAR, Chapter [6]. 1 2 3 U 14

2. FSAR, Chapter [15]. 1 2 4
3. Regulatory Guide 1.93, December 1974. 1 5
4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes 1 to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-8 Rev. 5.0 1

Distribution Systems - Operating B 3.8.9 Table B 3.8.9-1 (page 1 of 1)

AC and DC Electrical Power Distribution Systems TYPE VOLTAGE TRAIN A* TRAIN B*

AC safety buses [4160 V] [ESF Bus] [NB01] [ESF Bus] [NB02]

[480 V] Load Centers Load Centers

[NG01, NG03] [NG02, NG04]

[480 V] Motor Control Motor Control Centers Centers

[NG01A, NG01I, [NG02A, NG02I, NG01B, NG03C, NG02B, NG04C, NG03I, NG03D] NG04I, NG04D]

[120 V] Distribution Panels Distribution Panels 1

[NP01, NP03] [NP02, NP04]

DC buses [125 V] Bus [NK01] Bus [NK02]

Bus [NK03] Bus [NK04]

Distribution Panels Distribution Panels

[NK41, NK43, NK51] [NK42, NK44, NK52]

AC vital buses [120 V] Bus [NN01] Bus [NN02]

Bus [NN03] Bus [NN04]

  • Each train of the AC and DC electrical power distribution systems is a subsystem.

INSERT 5 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-9 Rev. 5.0 1

ITS 3.8.9 1

INSERT 5 Table B 3.8.9-1 (page 1 of 1)

Unit 3 AC and DC Electrical Power Distribution System TYPE VOLTAGE TRAIN A TRAIN B AC safety bus 4160 V Bus 3A Bus 3B Bus 4A(a) Bus 4B(a) 480 V Load Center Load Centers 3A, 3C, 3H(b) 3B, 3D, 3H(b)

DC bus 125 V Bus 3A Bus 3B Bus 4A Bus 4B AC vital Panel 120 V 3P07, 3P22 3P06, 3P21 4P22(a) 4P06(a), 4P21(a) 3P09, 3P24 3P08, 3P23 4P09(a), 4P24(a) 4P08(a), 4P23(a)

(a) As required to meet LCO 3.8.9.b and 3.8.9.e.

(b) Swing load center bus can be aligned to either train.

INSERT Page B 3.8.9-9a

ITS 3.8.9 1

INSERT 5 (cont.)

Table B 3.8.9-2 (page 1 of 1)

Unit 4 AC and DC Electrical Power Distribution System TYPE VOLTAGE TRAIN A TRAIN B AC safety bus 4160 V Bus 4A Bus 4B Bus 3A(a) Bus 3B(a) 480 V Load Center Load Centers 4A, 4C, 4H(b) 4B, 4D, 4H(b)

DC bus 125 V Bus 4A Bus 4B Bus 3A Bus 3B AC vital Panel 120 V 4P07, 4P22 4P06, 4P21 3P07(a), 3P22(a) 3P06(a), 3P21(a) 4P09, 4P24 4P08, 4P23 3P24(a) 3P23(a)

(a) As required to meet LCO 3.8.9.b and 3.8.9.e.

(b) Swing load center bus can be aligned to either train.

INSERT Page B 3.8.9-9b

JUSTIFICATION FOR DEVIATIONS ITS 3.8.9 BASES, DISTRIBUTION SYSTEMS - OPERATING

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
3. Changes are made to be consistent with changes made to the Specification.
4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING There are no specific No Significant Hazards Considerations for this Specification.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

ATTACHMENT 10 ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

ITS ITS 3.8.10 A01 A.C. SOURCES SHUTDOWN Add proposed LCO 3.8.10 M01 LIMITING CONDITION FOR OPERATION See ITS LCO 3.8.10 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE: 3.8.2

a. One startup transformer and associated circuits, or an alternate circuit, between the offsite transmission network and the 4160 volt bus, A or B, and
b. One diesel generator with:
1) For Unit 3 (3A or 3B)

A skid-mounted fuel tank and a day fuel tank, with an OPERABLE solenoid valve to permit gravity flow from the day tank to the skid mounted tank, with the two tanks together containing a minimum of 2000 gallons of fuel oil For Unit 4 (4A or 4B)

A day fuel tank containing a minimum volume of 230 gallons of fuel

2) A fuel storage system containing a minimum volume of fuel of 38,000 gallons (Unit 3).

34,700 gallons (Unit 4)**

3) An associated fuel transfer pump** See ITS See ITS 3.8.3 3.8.2
4) For Unit 3 only, lubricating oil storage containing a minimum volume of 120 gallons of lubricating oil
5) For Unit 3 only capability to transfer lubricating oil from storage to the diesel generator unit and M01 R2
6) Energized MCC bus (as identified by Specification 3.8.1.1.b.).

See ITS Applicability APPLICABILITY: MODES 5* and 6*. 3.8.2 During movement of irradiated fuel assemblies M02 ACTION:

Add proposed ACTIONS Note NOTE: Enter the ACTION of LCO 3.8.3.2, Onsite Power Distribution - Shutdown, with one required train de-energized as a result of inoperable offsite circuit.

With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, movement of irradiated fuel, or crane operation with loads over the fuel storage pool, and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the Reactor Coolant System through a greater than or equal to 2.2 square inch vent. In addition, when in MODE 5 with the reactor coolant loops not filled, or in MODE 6 with the water level less than 23 feet above the reactor vessel flange, immediately initiate corrective action to restore the required sources to OPERABLE status as soon as possible and increase RCS inventory as soon as possible.

See ITS See ITS

  • CAUTION - If the opposite unit is in MODES 1. 2. 3, or 4 see Specification 3.8.1.1 3.8.2 3.8.3
    • A temporary Class III fuel storage system containing a minimum volume of 38,000 gallons of fuel oil may be used for up to 10 days during the performance of Surveillance Requirement 4.8.1.1.2i.1 for the Unit 3 storage tank while Unit 3 is in Modes 5, 6, or defueled. If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively.

TURKEY POINT - UNITS 3 & 4 3/4 8-11 AMENDMENT NOS. 287 AND 281

ITS ITS 3.8.10 A01 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the requirements of Specifications 4.8.1.1.1.a and 4.8.1.1.2 (except for Specification 4.8.1.1.2a.5).

See ITS 3.8.2 TURKEY POINT - UNITS 3 & 4 3/4 8-12 AMENDMENT NOS. 181 AND 175

ITS ITS 3.8.10 A01 ONSITE POWER DISTRIBUTION SHUTDOWN LIMITING CONDITION FOR OPERATION Add proposed LCO 3.8.10 M01 LCO 3.8.10 3.8.3.2 As a minimum, the following electrical busses shall be energized in the specified manner:

M01 R2

a. One train of A.C. emergency busses associated with the unit (3.8.3.1a. or b.) consisting of one 4160-volt and three 480-volt A.C. emergency busses load centers* and three (four for Unit 4 Train A) vital sections of motor control center busses, See ITS 3.8.8
b. Two 120-volt A.C. vital busses for the unit energized from their associated inverters** connected to their respective D.C. busses, and See ITS 3.8.5 A02 R2
c. Three 125-volt D.C. busses energized from their associated battery banks.

Applicability APPLICABILITY MODES 5*** and 6***. M02 During movement of irradiated fuel assemblies ACTION:

Add proposed ACTIONS Note L01 With any of the above required electrical busses not energized in the required manner, immediately suspend all Action A operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel, initiate corrective action to energize the required electrical busses in the specified manner as soon as possible, and L02 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the RCS through at least a 2.2 square inch vent.

Add proposed Required Actions A.2.1 and A.2.2 Add proposed Required Action A.1 SURVEI LLANCE REQUIREMENTS L03 M01 SR 3.8.10.1 4.8.3.2 The specified busses shall be determined energized in the required manner by verifying correct breaker alignment and indicated voltage on the busses in accordance with the Surveillance Frequency Control Program.

L01 Add proposed Required Action A.2.4 M03 A03 R2

  • With the opposite unit in MODE 1, 2, 3, or 4, the 480-volt load centers can only be cross-tied upon issuance of an engineering evaluation to prevent exceeding required electrical components maximum design ratings and to ensure availability of the minimum required equipment. See ITS 3.8.8
    • A backup inverter may be used to replace the normal inverter provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time.

A02 R2

      • CAUTION - If the opposite unit is in MODES 1, 2, 3, or 4, see the corresponding Limiting Condition for Operation 3.8.3.1.

TURKEY POINT - UNITS 3 & 4 3/4 8-23 AMENDMENT NOS. 263 AND 258

DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.8.3.2 (ITS 3.8.10) is applicable in MODES 5 and 6. The CTS 3.8.3.2 Applicability is modified by a Note *** which states, "CAUTION - If the opposite unit is in MODES 1, 2, 3, or 4, see the corresponding Limiting Condition for R2 Operation 3.8.3.1." ITS 3.8.10 does not contain a similar Note. This changes the CTS by deleting a requirement that is redundant to CTS 3.0.5, which is retained in ITS.

The purpose of the CTS 3.8.3.2 Applicability Note is to ensure appropriate action requirements are performed for equipment shared between both units when required for a specific MODE of operation. This Note is redundant to the generic requirement provided in CTS 3.0.5 (ITS LCO 3.0.10) and, therefore, is not necessary. CTS 3.0.5 states, in part, "Limiting Conditions for Operation including the associated ACTION requirements shall apply to each unit individually unless otherwise indicated This requirement is retained in ITS LCO 3.0.10. As a result, Technical Specification requirements are applicable to each unit and R2 apply, based on the units applicable MODE, to the requirements associated with an LCO that refers to systems and components shared by both units, irrespective of whether an explicit statement is provided or not. The appropriate Technical Specification ACTIONS associated with shared systems will continue to be performed for each unit based on the units applicable MODE or specified condition per the requirements of ITS LCO 3.0.10. This change is designated as an administrative change and is acceptable because the change does not result in technical changes to the CTS.

A03 CTS 3.8.3.2 requires one train of A.C. emergency busses associated with the unit consisting of, in part, three 480-volt A.C. emergency busses load centers.

The 480V load center requirement is modified by footnote

  • which states, With the opposite unit in MODE 1, 2, 3, or 4, the 480-volt load centers can only be cross-tied upon issuance of an engineering evaluation to prevent exceeding required electrical components maximum design ratings and to ensure R2 availability of the minimum required equipment. ITS LCO 3.8.10 requires the necessary portion of AC and DC electrical power distribution trains, and AC vital electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. This changes the CTS by not including the statement when 480V load centers can be cross-tied.

Turkey Point Unit 3 and Unit 4 Page 1 of 6

DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN The purpose of the

  • footnote associated with CTS 3.8.3.2 is to prevent exceeding required electrical components maximum design ratings and to ensure availability of the minimum required equipment if a 480V load center is cross-tied while the opposite unit is in MODE 1, 2, 3, or 4. This footnote is unnecessary since an engineering evaluation has already been performed to determine the acceptability of closing cross-tie breakers on 480V load centers during shutdown conditions considering the opposite unit is in MODE 1, 2, 3, or 4 and incorporated R2 in plant operational procedures, as applicable. The evaluation determined the required electrical components maximum design ratings were not exceeded and the minimum required equipment continues to be available when required. This change is designated as an administrative change because the deleted requirement has already been accomplished and, thus, does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.1.2.b.6 requires, in part, one Emergency Diesel Generator (EDG) with an energized motor control center (MCC) bus (as identified by Specification 3.8.1.1.b). CTS 3.8.3.2 states, in part, that as a minimum, the R2 following AC buses shall be energized in the specified manner and then lists the applicable busses and how the buses are energized. ITS Limiting Condition for Operation (LCO) 3.8.10 states that the necessary portion of AC and DC electrical R2 power distribution trains, and AC vital electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. In addition, an optional Required Action (ITS 3.8.10, Required Action A.1) has been added which allows the associated supported required feature(s) to be declared inoperable. This changes the CTS by requiring those necessary portions of electrical power distribution trains and subsystems to be OPERABLE to support R2 equipment required to be OPERABLE, which could require more distribution buses or panels to be OPERABLE than is currently required. In addition, an action has been added to allow an option to the existing actions.

The purpose of CTS 3.8.1.2.b.6 and CTS 3.8.3.2 is to ensure that a minimum number of electrical buses are energized (i.e., OPERABLE). This change adds a requirement that the applicable portions of AC and DC electrical power R2 distribution trains, and AC vital electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE by the Technical Specifications. This added restriction conservatively assures the needed electrical power distribution boards and panels are OPERABLE, even if this results in both trains of one or more of the electrical power distribution systems being required. Because the ITS 3.8.10 requirements require the necessary R2 portions of the distribution trains and subsystems to be OPERABLE to support equipment required to be OPERABLE, if a portion of the electrical power distribution train or subsystem cannot supply any required equipment, that R2 electrical power distribution train or subsystem is inoperable. In this event, it may not be necessary to suspend irradiated fuel handling and positive reactivity additions. Conservative actions can be assured if all required equipment without the necessary power is declared inoperable, and the associated ACTIONS of the individual equipment is taken (ITS 3.8.10, Required Action A.1). Therefore, Turkey Point Unit 3 and Unit 4 Page 2 of 6

DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN along with the conservative additional requirements placed on the electrical power distribution trains and subsystems, Required Action A.1, which requires R2 the associated supported equipment to be declared inoperable, is also added.

These changes are acceptable because the additions represent restrictions consistent with implicit assumptions for operation in shutdown conditions (required equipment receiving the necessary required power). This change is designated as more restrictive because it adds a new requirement to the CTS, where more buses may be required to be OPERABLE in ITS than in CTS.

M02 CTS 3.8.1.2 and CTS 3.8.3.2 are applicable in MODES 5 and 6. ITS 3.8.10 is applicable in MODES 5 and 6 and during movement of irradiated fuel assemblies and has an ACTIONS Note stating that LCO 3.0.3 is not applicable. This changes the CTS by adding the Applicability of "During movement of irradiated fuel assemblies," and adds a Note to the ACTIONS stating that LCO 3.0.3 is not applicable.

This change is acceptable because the proposed requirements are necessary to ensure the electrical power distribution trains and subsystems are OPERABLE to R2 support equipment required to be OPERABLE during movement of irradiated fuel assemblies. Movement of fuel normally occurs during MODES 5 and 6; however, it can also occur outside of containment in other plant MODES (MODES 1, 2, 3, and 4) or other conditions (i.e., reactor defueled). This addition to the applicability is needed to ensure the appropriate electrical distribution system requirements are specified during fuel handling and to ensure the appropriate actions are taken (i.e., stop fuel movement) when the minimum electrical supply is not available. In addition, this change adds a clarification Note stating that LCO 3.0.3 is not applicable because LCO 3.0.3 has no Required Actions that restore safety with respect to the movement of irradiated fuel. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable because LCO 3.0.3 applicability is limited to MODES 1, 2, 3, and 4 only with a designated endpoint of MODE 5. In addition, if moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with ITS 3.8.10 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shut down, but would not require suspension of the activities with a potential for releasing radioactive materials. This change is designated as more restrictive because the ITS requires equipment to be OPERABLE during movement of irradiated fuel assemblies both inside and outside of the containment, not only when in MODES 5 and 6.

M03 CTS 3.8.3.2 Action does not contain a Required Action to declare associated required residual heat removal subsystem(s) inoperable and not in operation.

ITS 3.8.10, Required Action A.2.4, requires that when one or more required AC or DC electrical power distribution trains, or AC vital electrical power distribution R2 subsystems are inoperable to declare the associated required residual heat removal (RHR) subsystem(s) inoperable and not in operation unless the associated supported required feature(s) were declared inoperable. This changes the CTS by potentially requiring declaring the associated required Turkey Point Unit 3 and Unit 4 Page 3 of 6

DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN residual heat removal subsystem(s) inoperable and not in operation when one or more required AC or DC electrical power distribution trains, or AC vital electrical R2 power distribution subsystems are inoperable.

This change is acceptable because notwithstanding performance of the other Required Actions, a required RHR subsystem may be inoperable. In this case, the other Required Actions do not adequately address the concerns relating to coolant circulation and heat removal and pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered. Therefore, Required Action A.2.4 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions. This change is designated as more restrictive because additional Required Actions may be taken in the ITS then are in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None R2 LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.8.3.2 states that as a minimum, the following electrical busses shall be energized in the specified manner with a specific manner of energization, then provides a list of buses with a specific manner of energization listed for the 120 VAC vital buses and the 125 VDC buses. In addition, CTS 3.8.3.2 ACTION provides actions to perform if R2 the buses are not energized in the required manner: ITS 3.8.10 states that the necessary portion of AC and DC electrical power distribution trains, and AC vital R2 electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. This changes the CTS by specifying how the buses must be energized, stating that the trains and subsystems must be R2 OPERABLE, thus relying on the definition of OPERABLE/OPERABILITY to decide the manner of energization.

The purpose of CTS 3.8.3.2 is to provide an LCO for the onsite power distribution system when shutdown. This change is acceptable because the LCO requirements continue to ensure that the trains and subsystems are maintained R2 consistent with the safety analyses and licensing basis. The ITS definition of OPERABLE states that a system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s). In addition, ITS Turkey Point Unit 3 and Unit 4 Page 4 of 6

DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN LCO 3.8.5, "DC Source - Shutdown," and ITS LCO 3.8.8, "Inverters -

Shutdown," provide requirements for the source of power to the DC buses and 120 VAC vital panels. This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.

L02 (Category 3 - Relaxation of Completion Time) CTS 3.8.3.2 ACTION requires, in part, that with any of the above required electrical buses not energized in the required manner, the Reactor Coolant System (RCS) must be depressurized and vented within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> through at least a 2.2 square inch vent. ISTS 3.8.10 does R2 not include this Required Action. ITS LCO 3.4.12, "Overpressure Mitigation System," provides requirements for RCS pressure relief when in MODES 4, 5, or 6 to depressurize and establish an RCS vent of 2.2 square inches within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the other pressure relief methods are incapable of limiting pressure. R2 his changes the CTS by relying on ITS LCO 3.4.12 to provide the Required Actions and allowing a longer Completion Time to depressurize the RCS and establish a 2.2 square inch RCS vent.

The purpose of CTS 3.8.3.2 Action is to provide remedial actions to be taken with any of the above required electrical buses not energized in the required manner while in MODE 5 or 6. One of these remedial actions is to depressurize and vent the RCS through at least a 2.2 square inch vent, which is being proposed for deletion. This change is acceptable because the CTS 3.8.3.2 ACTION to depressurize and vent the RCS is duplicative of the ITS LCO 3.4.12 Required Action to depressurize and vent the RCS. In addition, ITS 3.4.12 Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the allowed Completion Time. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L03 (Category 4 - Relaxation of Required Action) CTS 3.8.3.2 ACTION states, in part, that that with any of the above required electrical busses not energized in the required manner, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel.

ITS 3.8.10, Required Actions A.2.1 and A.2.2, provide Actions to be performed under similar conditions. These ITS Required Actions state to suspend movement of irradiated fuel assemblies and suspend operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN (SDM) or boron concentration. This changes the CTS Actions by deleting the requirement to suspend CORE ALTERATIONS and to clarify to only suspend positive reactivity additions when it could result in loss of required SDM or boron concentration.

The purpose of the CTS 3.8.3.2 ACTION is to minimize the possibility of an event that may need a required electrical bus to mitigate the consequences of the event. CORE ALTERATIONS is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting Turkey Point Unit 3 and Unit 4 Page 5 of 6

DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN reactivity, within the reactor vessel with the head removed and fuel in the vessel."

CORE ALTERATIONS only occur when the reactor vessel head is removed and only applies in MODE 6. There is only one accident considered during MODE 6 that involves CORE ALTERATIONS: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building.

Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, would not prevent or impair the mitigation of a fuel handling accident.

ITS 3.8.10 retains the requirement to suspend movement of irradiated fuel assemblies in ITS 3.8.10, Required Action A.2.1 (for one or more inoperable electrical power distribution buses). Therefore, because the only CORE ALTERATION analyzed in the safety analysis and potentially affected by a loss of an electrical power distribution bus is covered by the ITS Required Actions, deleting the reference to "CORE ALTERATIONS" is acceptable. Additionally, CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to R2 the 72-hour decay period is improbable because the physical time required to perform plant shutdown, cooldown, depressurize the RCS, and the additional operations required to expose the irradiated fuel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

CTS 3.8.3.2 ACTION also requires that with less than the above minimum required electrical busses, immediately suspend all operations involving positive reactivity changes while ITS 3.8.10, Required Action A.2.2, requires only suspending operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. This change is acceptable because it allows for positive reactivity additions that do not result in loss of required SDM or boron concentration (e.g., water addition or temperature change) assuring continued safe operation.

This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Turkey Point Unit 3 and Unit 4 Page 6 of 6

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

CTS Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown and DC electrical power distribution trains R2 3.8.1.2, LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power 3.8.3.2 DOC M01 distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

Applicability APPLICABILITY: MODES 5 and 6, DOC M02 During movement of [recently] irradiated fuel assemblies. 1 ACTIONS

NOTE-----------------------------------------------------------

DOC M02 LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME Action A. One or more required A.1 Declare associated Immediately DOC M01 AC, DC, or AC vital bus supported required or DC electrical electrical power feature(s) inoperable.

R2 power distribution distribution subsystems 2 trains inoperable. OR A.2.1 Suspend movement of Immediately

[recently] irradiated fuel 1 assemblies.

DOC L03 AND A.2.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.10-1 Rev. 5.0 2

CTS Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2.3 Initiate actions to restore Immediately required AC, DC, and AC and DC electrical vital bus electrical power R2 power distribution distribution subsystems to 2 trains OPERABLE status.

AND A.2.4 Declare associated Immediately required residual heat DOC M03 removal subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8.3.2 SR 3.8.10.1 Verify correct breaker alignments and voltage to [ 7 days required AC, DC, and AC vital bus electrical power 1 and DC electrical distribution subsystems. OR 2 R2 power distribution trains In accordance with the Surveillance Frequency Control Program ] 1 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.10-2 Rev. 5.0 2

JUSTIFICATION FOR DEVIATIONS ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN

1. The Improved Standard Technical Specification (ISTS) contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
2. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Distribution Systems - Shutdown B 3.8.10 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown BASES BACKGROUND A description of the AC, DC, and AC vital bus electrical power distribution R2 systems is provided in the Bases for LCO 3.8.9, "Distribution Systems -

Operating."

APPLICABLE The initial conditions of Design Basis Accident and transient analyses in 14 SAFETY U the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), assume 2 1 ANALYSES Engineered Safety Feature (ESF) systems are OPERABLE. The AC, DC, and AC vital bus electrical power distribution systems are designed to R2 provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the AC, DC, and AC vital bus electrical power R2 distribution system is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY. and DC electrical power distribution trains R2 The OPERABILITY of the minimum AC, DC, and AC vital bus electrical 2 power distribution subsystems during MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies ensures that: 1

a. The unit can be maintained in the shutdown or refueling condition for extended periods,
b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident [involving handling recently irradiated fuel. Due to radioactive decay, AC and DC electrical power is only required to mitigate fuel handling accidents 1 involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

The AC and DC electrical power distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.10-1 Rev. 5.0 2

Distribution Systems - Shutdown B 3.8.10 BASES trains, LCO Various combinations of subsystems, equipment, and components are 2 R2 required OPERABLE by other LCOs, depending on the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of required systems, equipment, and components - all specifically addressed in each LCO and implicitly required via the definition of OPERABILITY.

R2 Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the unit in a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents [involving handling recently irradiated fuel]). 1 R2 trains and 2 APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement of [recently] 1 irradiated fuel assemblies, provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,
b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 1 critical reactor core within the previous [X] days)] are available,
c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

and DC electrical power distribution trains 2

The AC, DC, and AC vital bus electrical power distribution subsystems R2 requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.10-2 Rev. 5.0 2

Distribution Systems - Shutdown B 3.8.10 BASES ACTIONS (continued)

A.1, A.2.1, A.2.2, A.2.3, and A.2.4 Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem train may be capable of supporting sufficient required features to allow continuation of [recently] irradiated 1 fuel movement. By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend movement of [recently] irradiated fuel assemblies, and operations 1 involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal (RHR) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered. Therefore, Required Action A.2.5 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions.

Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.10-3 Rev. 5.0 2

Distribution Systems - Shutdown B 3.8.10 BASES ACTIONS (continued)

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

SURVEILLANCE SR 3.8.10.1 REQUIREMENTS and DC electrical power distribution trains This Surveillance verifies that the AC, DC, and AC vital bus electrical required 2 R2 power distribution subsystems are functioning properly, with all the buses energized. The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses.

[ The 7 day Frequency takes into account the capability of the electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions. 1 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 3 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

U REFERENCES 1. FSAR, Chapter [6]. 2 1 U 14

2. FSAR, Chapter [15]. 2 1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.10-4 Rev. 5.0 2

JUSTIFICATION FOR DEVIATIONS ITS 3.8.10 BASES, DISTRIBUTION SYSTEMS - SHUTDOWN

1. The Improved Standard Technical Specification (ISTS) contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
3. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

Specific No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN There are no specific No Significant Hazards Considerations for this Specification.

Turkey Point Unit 3 and Unit 4 Page 1 of 1

ATTACHMENT 11 Relocated/Deleted Current Technical Specifications (CTS) in the Turkey Point Unit 3 and Unit 4 ITS Conversion NONE

ATTACHMENT 12 Improved Standard Technical Specifications (ISTS)

Not Adopted in the Turkey Point Unit 3 and Unit 4 ITS Conversion NONE

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